Compliance

PFAS state-by-state filing checklist

What to file, where, when, and the supporting documents for each of the 6 states Aleph tracks.

Six states have active PFAS disclosure or filing requirements as of 2026 — California, Maine, New York, Washington, Colorado, Connecticut. 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 (LD 1503) — broadest requirement:

  • What: annual disclosure of all products containing intentionally-added PFAS, by SKU and PFAS class
  • Where: Maine DEP online portal
  • When: annually by January 1 (calendar year prior)
  • Documents needed: TOF or targeted lab results, supplier disclosures identifying intentionally-added PFAS by name, product category mapping
  • Pitfall: "intentionally-added" is broader than many companies assume — PTFE coatings, treated textiles, and waterproof packaging all count

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: Maine LD 1503 is the only one that requires a proactive annual filing. The other five are continuous-compliance regimes — meaning your evidence file is your defense, not a submitted form. Build the file once; reuse across all six.

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.

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