PFAS state-by-state filing checklist

Seven states have active PFAS disclosure, filing or certificate requirements as of 2026 — California, Maine, Minnesota, New York, Washington, Colorado, Connecticut. Minnesota is the one with an imminent filing deadline. Each has its own form, portal, and deadline. Missing a Maine annual report is a different kind of problem than missing a California cosmetics filing.

Maine (38 MRSA §1614):

• What: no general annual disclosure. Notification to Maine DEP is required only for products the department has determined to be a currently unavoidable use (§1614(2)). Separately, on request you must supply a certificate that the product contains no intentionally-added PFAS, within 30 days (§1614(8)(A))
• When: the certificate is on-demand, so the substantiation has to exist before you are asked — 30 days is not enough time to start testing
• Who: "manufacturer" expressly includes the importer or first domestic distributor of an imported product (§1614(1)(E)) — being the importer rather than the factory does not move this duty off you
• Sales bans: phased — cookware, cosmetics, cleaning products, juvenile products, textiles and more from 1 Jan 2026; artificial turf and severe-weather outdoor apparel from 2029; all remaining products from 2032
• Documents needed: supplier disclosures identifying intentionally-added PFAS by name; lab results where a supplier cannot attest
• Pitfall: "intentionally-added" is broader than many companies assume — PTFE coatings, treated textiles, and waterproof packaging all count

Minnesota (Minn. Stat. §116.943, "Amara’s Law") — the one with a live deadline:

• What: report every product with intentionally-added PFAS to the MPCA — product description with UPC or SKU, what the PFAS does, and the amount of each PFAS by CAS number (subd. 2(a))
• When: 15 September 2026. The statutory date was 1 Jan 2026; the commissioner extended it to 1 July and then to 15 September 2026. A further extension to 14 December 2026 required a request postmarked by 16 August 2026
• Scope: only products manufactured after 1 July 2023 — a 2026 amendment narrowed it, and it is easy to miss
• Who: "manufacturer" reaches the importer or first domestic distributor only where the producer or brand owner has no US presence (subd. 1(o)) — narrower than Maine
• Also: on request, a certificate of no intentionally-added PFAS including testing results (subd. 4(b)) — Minnesota names the test results where Maine does not, so a supplier attestation alone may satisfy Maine and not Minnesota
• Sales bans: 11 categories from 1 Jan 2025; all remaining products from 2032

California (AB 1817 + AB 2771) — apparel and cosmetics bans:

• What: prohibition on selling apparel or cosmetics with intentionally-added PFAS as of 2025/2027 phased
• Where: no central filing — enforcement is by California DTSC + private actions
• When: continuous compliance; no annual report
• Documents needed: lab tests showing intentionally-added PFAS absence, supplier attestations, reformulation evidence for previously-PFAS-containing SKUs
• Pitfall: retailer pull dates (Target, Sephora) often precede the regulatory date — track customer compliance deadlines, not just California's

New York (S 6291) — apparel ban:

• What: ban on apparel with intentionally-added PFAS effective 2025
• Where: NY DEC enforcement, no central filing
• When: continuous; outdoor apparel ban extends 2028
• Documents needed: same as California apparel

Washington (Safer Products for WA — SCPA):

• What: restrictions on PFAS in 5 priority product categories (carpets, leather, food packaging, more added quarterly)
• Where: WA Ecology online reporting for designated priority products
• When: rolling — depends on product category designation date
• Documents needed: product composition disclosure, alternative-assessment if claiming a permitted use

Colorado (HB 22-1345):

• What: phased product bans across cookware, cosmetics, textiles, food packaging
• Where: CO Dept of Public Health enforcement, no central filing
• When: phased 2024–2027 by category
• Documents needed: lab tests, supplier attestations, alternative-product evidence

Connecticut (HB 6486):

• What: intentionally-added PFAS prohibited in food packaging
• Where: CT DEEP enforcement, no central filing
• When: effective 2024 for food packaging; broader bans pending
• Documents needed: food-contact substance disclosures, supplier attestations

TIP: ⚠️ Minnesota is the one with a proactive filing, and it is imminent — an MPCA report due 15 September 2026. Maine does NOT require a general annual filing: notification there applies only to products determined a currently unavoidable use. The rest are continuous-compliance regimes — meaning your evidence file is your defence, not a

WARNING: All six states define "intentionally-added" PFAS slightly differently. Maine is the broadest — anything beyond trace contamination counts. California's apparel rule sets a 100 ppm TOF threshold below which a product isn't considered intentionally-added. Check the specific definition before claiming exemption.