PFAS state-by-state filing checklist

This checklist covers seven states: California, Maine, Minnesota, New York, Washington, Colorado and Connecticut. It is not a complete list of states with PFAS laws, and these laws are amended often, so check the current text before relying on a date. Aleph doesn't file any of these reports or notifications for you.

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" means the maker or brand owner. For an imported product it includes the importer or first domestic distributor only if the maker or brand owner has no presence in the United States (§1614(1)(E))
• Sales bans: phased, ending with all remaining products from 2032
• Documents needed: supplier disclosures identifying intentionally added PFAS by name; lab results where a supplier cannot attest
• Note: "intentionally added PFAS" includes degradation by-products of PFAS (§1614(1)(D))

Minnesota (Minn. Stat. §116.943, "Amara’s Law"):

• What: report each product with intentionally added PFAS to the MPCA, with a product description including UPC or SKU, the purpose of the PFAS, and the amount of each PFAS by CAS number (subd. 2(a))
• When: the statute says January 1, 2026, but the MPCA extended the initial deadline to September 15, 2026, which has passed. Manufacturers granted an extension have until December 14, 2026. After that, the MPCA says reports are due each year on February 1
• Scope: only products manufactured after July 1, 2023, a limit added by a 2026 amendment
• Who: "manufacturer" reaches the importer or first domestic distributor only where the maker or brand owner has no presence in the United States (subd. 1(o))
• Also: if the MPCA directs testing and it shows no intentionally added PFAS, the certificate you provide must include the testing results (subd. 4(b))
• Sales bans: 11 product categories from January 1, 2025; all remaining products from January 1, 2032, unless the use is a currently unavoidable use

California (Health and Safety Code 108970–108971 and 108981.5):

• What: textile articles, including apparel, may not contain regulated PFAS from January 1, 2025, meaning PFAS intentionally added, or total organic fluorine at or above 100 ppm (50 ppm from January 1, 2027). Cosmetics with intentionally added PFAS are banned from January 1, 2025
• When: continuous compliance; outdoor apparel for severe wet conditions is exempt until January 1, 2028 but meanwhile must carry the disclosure "Made with PFAS chemicals"
• Documents needed: the manufacturer of a textile article must give the people selling it in California a signed certificate of compliance (HSC 108971(c)); keep lab results and supplier attestations behind it

New York (ECL 37-0121):

• What: apparel with intentionally added PFAS banned from January 1, 2025; outdoor apparel for severe wet conditions from January 1, 2028. The law also provides for a PFAS level to be set by regulation
• Who: the importer or first domestic distributor counts as the manufacturer only if the maker or brand owner has no presence in the United States
• Documents needed: a certificate of compliance signed by an authorized official of the manufacturer; lab tests and supplier attestations behind it

Washington (RCW 70A.350; WAC 173-337):

• What: restrictions on intentionally added PFAS in named product categories (for example, carpets and rugs and aftermarket stain and water treatments from January 1, 2025, and apparel and accessories from January 1, 2027), and a reporting duty for others (for example, cookware and footwear)
• Where and when: reporting products need a notice to Ecology through its notification database, due by January 31 of the year after the reporting requirement takes effect and annually by January 31 after that (WAC 173-337-060)
• Who: the importer or first owner in the United States is third in line to report, after the manufacturer and brand owner, if they have no US presence (WAC 173-337-060(1)(c))

Colorado (C.R.S. 25-15-604):

• What: bans on intentionally added PFAS by product category, phased from January 1, 2024. Cookware was a labeling requirement under HB 22-1345; SB 24-081 turned it into a ban from January 1, 2026, and extends bans to textile articles, including apparel, from January 1, 2028
• When: continuous compliance, by the category's date
• Documents needed: lab tests and supplier attestations showing no intentionally added PFAS

Connecticut (Public Acts 21-191 and 24-59):

• What: food packaging with intentionally added PFAS banned no later than December 31, 2023. From July 1, 2026, 12 product categories (including apparel, cookware, cosmetics, and children's products) with intentionally added PFAS need prior written notification to the department and labeling; from January 1, 2028 they may not be sold
• Documents needed: a certificate of compliance, which the department can request in writing

TIP: Filing duties are the exception: Minnesota's MPCA report, Washington's annual notice for reporting categories, Connecticut's prior notification, and Maine's notification for a currently unavoidable use. Otherwise these are continuous-compliance laws, where your evidence file is your defense, not a submitted form. Build the file once and reuse it across states.

WARNING: The states define PFAS terms differently. Maine's "intentionally added PFAS" includes degradation by-products, while California's textile law also counts PFAS measured at or above its total organic fluorine threshold even when nobody added it on purpose. Check each state's definition before claiming an exemption.