Important Year-End Developments in PFAS State Law: Minnesota, New Mexico, and Connecticut

States continue to advance restrictions and disclosure requirements for products that contain per- and polyfluoroalkyl substances (PFAS). State regulators are increasingly using rulemaking to implement and better define the scope of statutory PFAS-in-products obligations, particularly with respect to:

• Product labeling and disclosure
• Manufacturer reporting
• Definitions of “intentionally added PFAS”
• Exemptions and phase-in periods

Recent developments in Minnesota, New Mexico, and Connecticut reflect the differing regulatory approaches. This Advisory highlights recent PFAS actions in these three states, identifies key dates and upcoming deadlines, and offers practical considerations for product manufacturers. It is important to note, however, that a number of other states have already codified PFAS regulations, and many other states are considering similar actions.¹

Minnesota: Phased Product Restrictions and Reporting Obligations

Minnesota’s PFAS statute (Minn. St. § 116.943), known as Amara’s Law, imposes phased restrictions on products with “intentionally added” PFAS and requires manufacturers to report product information to the Minnesota Pollution Control Agency (MPCA). Under the Minnesota statute, “intentionally added” means “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.”

As of January 1, 2025, the law prohibits the sale, offering for sale, or distribution in Minnesota of eleven categories of products containing intentionally added PFAS. Prohibited product categories include, among others, carpets and rugs, cookware, cosmetics, cleaning products, dental floss, juvenile products, menstruation products, ski wax, textile furnishings, and upholstered furniture.

Covered entities should be aware of the following additional requirements and compliance timelines:

Manufacturer reporting obligations beginning July 1, 2026: Manufacturers of products sold or distributed in Minnesota that contain intentionally added PFAS must report specified product and chemical information to the MPCA. While the statute originally contemplated an earlier reporting date, MPCA guidance and rulemaking have extended the initial reporting deadline to July 1, 2026, with ongoing updates required annually in February thereafter.

Broader prohibition beginning January 1, 2032: A general prohibition will apply to all products containing intentionally added PFAS, unless the MPCA determines by rule that the use constitutes a “currently unavoidable use.”

New Mexico: Expansive Product Restrictions and Manufacturer Reporting

New Mexico has enacted a comprehensive PFAS statute (HB 212) that establishes broad restrictions on intentionally added PFAS in consumer products, coupled with manufacturer reporting requirements. In New Mexico, “intentionally added” means “a per- or poly-fluoroalkyl substance deliberately added or used during the manufacture of a product where the continued presence, at any level or concentration, of the per- or poly-fluoroalkyl substance is desired or expected in the final product or one of the product’s components.” While the law is expansive, it also features 16 statutory exemptions, including, notably, for fluoropolymers.

Manufacturers whose products are sold in New Mexico should closely monitor the following requirements and phased compliance milestones:

Product prohibitions beginning January 1, 2027: Manufacturers may not sell, offer for sale, or distribute in New Mexico certain categories of consumer products containing intentionally added PFAS, including cookware, food packaging, dental floss, and juvenile products.

Manufacturer reporting requirements beginning January 1, 2027: Manufacturers of products containing intentionally added PFAS that are sold or distributed in New Mexico must submit specified product and chemical information to the New Mexico Environment Department. Updates to reporting are due annually on February 1.

Expanded product prohibitions beginning January 1, 2028: Additional consumer product categories become subject to PFAS restrictions, including carpets and rugs, cleaning products, cosmetics, fabric treatments, feminine hygiene products, textiles and textile furnishings, ski wax, and upholstered furniture.

Comprehensive prohibition beginning January 1, 2032: The sale or distribution of all products containing intentionally added PFAS will be prohibited unless the Environmental Improvement Board adopts a rule designating the PFAS use as a “currently unavoidable use.”

Connecticut: Labeling Order Implementing Disclosure Requirements

In December 2025, the Connecticut Department of Energy and Environmental Protection (DEEP) issued a final labeling order under the state’s PFAS-in-products law. The order provides clarity on how manufacturers must label products containing intentionally added PFAS beginning in mid-2026 and represents a key compliance milestone for companies selling covered products in Connecticut. In Connecticut, “intentionally added” means “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.”

In addition to the state’s specific product prohibitions identified in the table below, manufacturers should be aware of the following near-term labeling obligations in Connecticut:

Labeling requirements beginning July 1, 2026: Beginning July 1, 2026, labeling applies to specified product categories that contain intentionally added PFAS, including apparel, carpets and rugs, cleaning products, cookware, cosmetics, dental floss, fabric treatments, children’s products, menstruation products, textile furnishings, ski wax, and upholstered furniture.

Approved labeling language: DEEP has approved specific words and phrases that manufacturers may use to satisfy the PFAS labeling requirement, including “Contains PFAS,” “Made with PFAS,” “Made with PFAS chemicals,” “Made with intentionally added PFAS,” and similar language if approved by the agency.

Figure 1. Summary of PFAS-Related Product Prohibitions in Connecticut, Minnesota, and New Mexico
State	Deadline	Requirement	Covered Product
Minnesota	Jan. 1, 2025	Prohibition on sale, offer for sale, or distribution of specified products	Carpets and rugs; cookware; cosmetics; cleaning products; dental floss; juvenile products; menstruation products; ski wax; textile furnishings; upholstered furniture
	Jan. 1, 2032	Prohibition on all products with intentionally added PFAS	All products, unless deemed a currently unavoidable use
New Mexico	Jan. 1, 2027	First phase of product prohibitions	Cookware; food packaging; dental floss; juvenile products
	Jan. 1, 2028	Expanded product prohibitions	Carpets and rugs; cleaning products; cosmetics; fabric treatments; feminine hygiene products; textiles; textile furnishings; ski wax; upholstered furniture
	Jan. 1, 2032	Prohibition on all products with intentionally added PFAS	All products, unless deemed a currently unavoidable use
Connecticut	Jan. 1, 2026	Targeted disclosure and notice requirements	Outdoor apparel for severe wet conditions; turnout gear
	July 1, 2026	Manufacturer notification and mandatory labeling	Apparel; carpets and rugs; cleaning products; cookware; cosmetics; dental floss; fabric treatments; children’s products; menstruation products; textile furnishings; ski wax; upholstered furniture
	Jan. 1, 2028	Prohibition on the manufacture, sale, offer for sale, or distribution of covered products	Apparel; carpets and rugs; cleaning products; cookware; cosmetics; dental floss; fabric treatments; children’s products; menstruation products; textile furnishings; ski wax; upholstered furniture; turnout gear; outdoor apparel for severe wet conditions

Looking Ahead

PFAS-in-products regulation continues to be largely state-specific and is highly dynamic. All companies that manufacture products distributed nationally, including retailers whose names appear on product labels sold in their own retail stores, should evaluate whether PFAS are intentionally added to their products, monitor rulemaking developments in addition to enacted statutes, and track state-specific timelines and agency guidance updates. As state requirements continue to multiply and diverge, multistate compliance strategies will become increasingly important.Arnold & Porter is actively monitoring PFAS developments nationwide, including additional state product bans, labeling requirements, and reporting obligations.  

© Arnold & Porter Kaye Scholer LLP 2025 All Rights Reserved. This Advisory is intended to be a general summary of the law and does not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.