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· 5 min read COMPLIANCE PFAS

PFAS Rules for Importers: Which States, Which Products

Which US states require PFAS disclosure, which ban outright, and what an importer actually has to file. Verified against each state's own statute.

JC
James Chang Written with AI
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PFAS is the compliance question importers ask us most often, and the honest answer is that there isn't one rule. There are several, and they don't agree with each other; which ones apply depends on what you sell and where you sell it.

Worse, the rules that get quoted in most summaries are frequently the old ones. Two of the biggest requirements moved in 2026 alone. So everything below is cited to the state's own statute or agency page, and checked on September 5, 2026. If you're reading this much later, check the links rather than the text.

The distinction almost everyone misses

There are two completely different kinds of state PFAS law, and confusing them is how importers end up doing the wrong work:

  • Reporting states want a filing. You tell them what PFAS is in your products, and you can keep selling.
  • Ban states don't want a filing at all. Past a date, listed categories simply cannot be sold, and no amount of paperwork changes that.

Maine is the clearest example of why this matters. It's widely described as a PFAS reporting state. It isn't anymore — and that's not a subtle change.

Maine: the reporting requirement was deleted

Maine's general notification requirement, the one scheduled to take effect on January 1, 2025, was eliminated. Maine DEP says so plainly on its own PFAS in Products page. Notification now applies only to products that have received a Currently Unavoidable Use determination, which come with a form and a fee.

What Maine has instead is a phased sales ban under 38 M.R.S. §1614:

From Prohibited with intentionally added PFAS
Jan 1, 2023 Carpets and rugs; fabric treatments
Jan 1, 2026 Cleaning products, cookware, cosmetics, dental floss, juvenile products, menstruation products, textile articles, ski wax, upholstered furniture
Jan 1, 2029 Artificial turf; outdoor apparel for severe wet conditions (unless labeled)
Jan 1, 2032 All remaining products, unless determined a Currently Unavoidable Use
Jan 1, 2040 HVAC and refrigeration equipment; refrigerants

That 2026 row is in force now. If you sell cookware or textiles into Maine with intentionally added PFAS, the issue isn't a late filing — it's that the product can't be sold there.

Minnesota: a reporting state, and the deadline is September 15

Minnesota's Amara's Law (Minn. Stat. §116.943) is the one with a filing, and this is the part worth acting on today.

The statute text says reports were due January 1, 2026. That is not the operative date. The MPCA has extended initial reports to September 15, 2026, filed through its PRISM system, with annual updates each February 1 afterward. A one-time extension to December 14, 2026 was available for requests postmarked by August 16, 2026.

Two things changed in 2026 that most summaries haven't caught up with:

  • The legislature narrowed the scope in May 2026. Products manufactured before July 1, 2023 are now out of the reporting requirement.
  • The deadline move was the agency's, not the legislature's. So the statute and the operative deadline genuinely say different things, and citing the statute alone gets you the wrong answer.

Minnesota is a ban state too, which is easy to miss. Since January 1, 2025, eleven categories with intentionally added PFAS — including carpets, cleaning products, cookware, cosmetics, juvenile products and textile furnishings — can't be sold there at all (subd. 5(a)). And it bans all products with intentionally added PFAS from January 1, 2032 unless the use is determined currently unavoidable (subd. 5(d)).

Connecticut and New Mexico

Connecticut (Conn. Gen. Stat. §22a-903c) required notification to DEEP by July 1, 2026 — a date that has already passed — with an $800 registration fee, across twelve categories including apparel, cookware, cosmetics, juvenile products and textile furnishings. Products in those categories have also needed approved on-pack PFAS labeling since the same date. The outright prohibition follows on January 1, 2028. If you sell into Connecticut in a covered category and haven't filed, that is the most urgent item on this page.

New Mexico's PFAS Protection Act rule took effect July 1, 2026, with reporting and labeling starting January 1, 2027 and the first prohibitions (cookware, food packaging, dental floss, juvenile products, firefighting foam) on the same date. There is still time to prepare for that one.

⚠️ This is not the full list. Colorado, Vermont, Washington, New York and others have their own dates and their own category lists. We've limited this article to the four we could verify line by line against the state's own materials, because a confidently-wrong table is worse than a short one.

"Intentionally added" does not mean the same thing twice

This is the definition everything turns on, and the states wrote it differently.

Minnesota (§116.943 subd. 1(l)) — PFAS "deliberately added during the manufacture of a product where the continued presence of PFAS is desired in the final product or one of the product's components to perform a specific function."

Maine (38 M.R.S. §1614) — "PFAS added to a product or one of its product components to provide a specific characteristic, appearance or quality or to perform a specific function." Maine then adds a clause Minnesota does not: "'Intentionally added PFAS' also includes any degradation by-products of PFAS."

Read those twice. Minnesota is about a function that is desired in the final product. Maine reaches things that were never meant to be in the final product at all. A supplier declaration written to satisfy one is not automatically evidence for the other.

You are probably the "manufacturer"

Importers routinely assume these laws land on the factory. They don't.

Both statutes define "manufacturer" to include the importer or first domestic distributor where the producer or brand owner has no US presence. Minnesota puts it at subd. 1(o); Maine uses near-identical wording. If you're bringing goods in from an overseas supplier under your own brand, the filing obligation is yours, and there is nobody upstream it can be handed to.

What an importer actually has to do

  1. Work out which of your products fall in a covered category, per state — not in general.
  2. Check the manufacture date. Minnesota now excludes anything made before July 1, 2023.
  3. Get a PFAS declaration from each supplier for the products that remain.
  4. Keep the declaration on the product record, not in an inbox.
  5. Re-check when a supplier changes materials, or a state changes its list.

Aleph helps with step 4: upload the declaration against the product it covers, with its date and an expiry, and Aleph alerts you before it lapses. Getting the declaration out of the supplier in step 3 is still your email, not ours.

The part most people get wrong

Supplier declarations expire, and material changes invalidate them. A declaration collected once is evidence about one moment, not a standing state of affairs — which is why the useful question is not "do we have a declaration" but "is the declaration we have still true."


This article is general information, not legal advice, and PFAS rules are moving quickly. Every date above is linked to the state's own statute or agency page — check those before acting, and talk to counsel about your specific catalog.

James Chang

Founder of Aleph. Building import compliance tools for US importers who are tired of spreadsheets and six-figure enterprise software.