PFAS is the compliance question importers ask us most often, and the honest answer is that there isn't one rule. There are several, they don't agree with each other, and 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 5 September 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. Maine is widely described as a PFAS reporting state. It isn't any more — 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 1 January 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 |
|---|---|
| 1 Jan 2023 | Carpets and rugs; fabric treatments |
| 1 Jan 2026 | Cleaning products, cookware, cosmetics, dental floss, juvenile products, menstruation products, textile articles, ski wax, upholstered furniture |
| 1 Jan 2029 | Artificial turf; outdoor apparel for severe wet conditions (unless labelled) |
| 1 Jan 2032 | All remaining products, unless determined a Currently Unavoidable Use |
| 1 Jan 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: the reporting state, and the deadline is 15 September
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 1 January 2026. That is not the operative date. The MPCA has extended initial reports to 15 September 2026, filed through its PRISM system, with annual updates each 1 February afterwards. A one-time extension to 14 December 2026 was available for requests postmarked by 16 August 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 1 July 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 also bans all products with intentionally added PFAS from 1 January 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 1 July 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 labelling since the same date. The outright prohibition follows on 1 January 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 1 July 2026, with reporting and labelling starting 1 January 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 2026–2027 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
- Work out which of your products fall in a covered category, per state — not in general.
- Check the manufacture date. Minnesota now excludes anything made before 1 July 2023.
- Get a PFAS declaration from each supplier for the products that remain.
- Keep the declaration on the product record, not in an inbox.
- Re-check when a supplier changes materials, or a state changes its list.
Aleph handles steps 3 and 4: you request a declaration from a supplier by link, they fill it in without needing an account, and it attaches to the product record when they complete it.
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 catalogue.