New Mexico Lawmaker Calls for Review of PFAS Exemptions

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Ahead of the Environmental Improvement Board’s (EIB’s) February 23 rulemaking hearing on regulations to implement New Mexico’s PFAS Protection Act, a New Mexico lawmaker has introduced legislation that could prompt renewed scrutiny of the statute’s product exemptions, including the exemption for fluoropolymers.

Introduced on January 29, 2026, House Joint Memorial 3 (HJM 3) would direct the New Mexico Environment Department (NMED) to develop a report on the implementation of the PFAS Protection Act, including the “efficacy” of rules promulgated by EIB.  NMED would also be required to assess the health, environmental, and economic risks associated with the act’s exemptions and provide recommendations “regarding whether such exemptions, such as the exemption for fluoropolymers, should be continued, modified or removed.”

HJM 3 characterizes the exemptions as having been adopted “based on limited scientific literature regarding chemical degradation, environmental mobility and persistence, potential human health pathways and possible health effects.”  The memorial specifically calls for additional research into “the toxicological profiles, exposure risks and public health implications of fluoropolymers.”

This legislative development comes less than a year before product phaseouts and reporting requirements take effect on January 1, 2027—as well as controversial PFAS labeling requirements proposed by NMED that would apply to nearly all products, including those exempted from prohibition and reporting requirements by the statute.

The PFAS Protection Act provides that EIB “may…adopt rules to carry out” the act’s provisions, “including requiring the labeling of products in English and Spanish.”  HJM 3, however, states that the PFAS Protection Act “requires” PFAS labeling, “including [for] products exempted from the phaseout and prohibition.”  The memorial further asserts that the statute does not exempt “products from other aspects of [EIB’s] authority” beyond phaseout and prohibition.

Revised Labeling Provisions in NMED’s Proposed Rule

Labeling remains a central component of NMED’s proposed rule to implement the PFAS Protection Act.  NMED petitioned the EIB to adopt the rule in October 2025, and the proposal is the subject of the February hearing.

On January 16, 2026, in response to comments, NMED released a revised proposal with several notable changes to the labeling requirements.

First, the revised proposal would exempt the following products from labeling requirements:

  • Products for which labeling requirements are preempted by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA),
  • Veterinary products and the packaging of veterinary products regulated by FDA, and
  • Medical devices, drugs, and the packaging of medical devices and drugs regulated by FDA.

Each of these product categories falls within exemptions included in the PFAS Protection Act.  However, the revised proposal does not extend labeling exemptions to other product categories that are exempt from prohibition or reporting requirements under the statute.

Second, the revised proposal eliminates the requirement that labels use “words and symbols approved by the department.”  Instead, the proposal would permit the following statements: “This product is made with PFAS,” “Made with PFAS,” or “Contains PFAS.”

NMED previously released draft labels containing health and environmental statements about PFAS.  While those labels may no longer be required, the proposal would still require product packaging to include a link to a New Mexico PFAS webpage, which currently makes health and environmental statements about PFAS as a class.

Third, the revised proposal adjusts the scope of the January 1, 2027, labeling effective date, allowing the continued sale and distribution of unlabeled products manufactured before that date.

Finally, the revised proposal clarifies the process for seeking waivers from labeling obligations and establishes associated fees.  The prerequisites for obtaining a waiver remain unchanged: for NMED to grant a waiver request, a product must be exempt from prohibition or reporting requirements and “none of the product’s material containing intentionally added [PFAS] will ever come into direct contact with a customer while the product is being used as intended during the useful life of the product.”

The EIB docket for the rulemaking can be found here.

New Jersey PFAS in Products Bill Awaits Governor’s Signature

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On December 22, 2025, New Jersey’s legislature passed SB 1042, which would restrict the use of intentionally added PFAS in cosmetics, carpet treatments, and food packaging, and impose additional labeling requirements for cookware.  If signed into law, New Jersey would join over a dozen states that have adopted similar restrictions.

The bill employs a familiar definition of PFAS: “any member of the class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom.”

Product Bans and Labeling Requirements

Two years after enactment, SB 1042 would ban the sale of the following products with intentionally added PFAS:

  • Cosmetics
  • Carpet or fabric treatments
  • Food packaging

In addition, two years after enactment, SB 1042 would require that cookware containing intentionally added PFAS in a handle or food contact surface include the statement “This product contains PFAS” on its product label.  This statement would be required in both English and Spanish and on online listings.

The bill provides the New Jersey Department of Law and Public Safety’s Division of Consumer Affairs significant enforcement authority, including civil penalties of up to $20,000 per day per violation and the ability to conduct random audits to ensure manufacturer compliance.

Exceptions and Exclusions

The bill includes several exemptions that may reduce compliance burdens for manufacturers:

  • Trace quantities: Intentionally added PFAS does not include “a technically unavoidable trace quantity of PFAS which stems from impurities of natural or synthetic ingredients or the manufacturing process, storage, or migration from packaging of the product or product component.”
  • Cosmetics: The prohibition does not extend to electronic components or internal components of cosmetic products.
  • Cookware: Products intended solely for commercial use are exempt. Cookware is also exempt from labeling if its surface area cannot accommodate a label of at least two square inches and it lacks an exterior container, wrapper, or tag.

Unlike some state-level PFAS legislation, SB 1042 does not establish specific limits on the amount of total organic fluorine in covered products.

Other Provisions

The bill directs the New Jersey Department of Environmental Protection (NJDEP) to:

  • Conduct PFAS research and environmental monitoring
  • Recommend additional product bans
  • Operate a source reduction program

The legislation appropriates $4.5 million for NJDEP to carry out these objectives.  NJDEP would be required to submit annual reports starting two years after enactment to summarize its findings.

More on SB 1042, known as the “Protecting Against Forever Chemicals Act,” can be found on the New Jersey Legislature’s website.

Update – January 18, 2026

On January 12, 2026, New Jersey Governor Phil Murphy signed SB 1042 into law.

Connecticut Releases Approved PFAS Label Language

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On December 1, 2025, the commissioner of Connecticut’s Department of Energy & Environmental Protection (DEEP) issued an order approving the following phrases that satisfy the state’s PFAS labeling requirements.  The approved language includes:

  • Contains PFAS
  • Made with PFAS
  • Made with PFAS chemicals
  • Made with intentionally added PFAS
  • This product contains PFAS chemicals

Manufacturers or producers can petition DEEP to approve other words or symbols.  Petitions must be submitted via email to DEEP.PFASInProduct@ct.gov.  Emails should include the proposed words or symbols, as well as the petitioner’s name, title, email address, and telephone number.

The order states that DEEP will publish and maintain an updated list of all approved labeling language on its PFAS in Products website.

Labeling Requirements

Beginning July 1, 2026, no person may sell or distribute certain products in Connecticut that contain intentionally-added PFAS unless the products include the required labeling disclosures.  A complete list of covered product categories can be found in a previous post.

Labeling is the responsibility of the manufacturer unless the wholesaler or retailer agrees to accept responsibility for their application.  Labels must:

  • Be clearly visible prior to sale
  • Use words or symbols approved by DEEP
  • Be sufficiently durable to remain legible for the product’s useful life

If a covered product is incorporated as a component of another product, the final product containing the component must be labeled.

Connecticut is not the only state that will soon impose PFAS labeling requirements.  Effective January 1, 2027, New Mexico will require labeling on all products containing intentionally added PFAS that are sold or distributed in the state.  More information on New Mexico’s requirements can be found here.

Massachusetts Introduces Comprehensive Children’s Product Chemicals Regulation Bill

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On November 10, 2025, a Massachusetts state senator introduced a bill that would create an extensive regulatory program to restrict the use of chemicals of concern—including PFAS—in children’s products sold in the state.

If enacted, SB 2660 would prohibit the use of intentionally added PFAS in children’s products above a total organic fluorine threshold set by the Massachusetts Department of Environmental Protection (MassDEP).  It would also allow MassDEP to screen chemicals, identify priority substances, and require their disclosure and eventual substitution in children’s products.

Children’s products are broadly defined as items “intended, made or marketed for use by children 12 years of age or under,” including toys, clothing, cosmetics, and jewelry, with specific exemptions (e.g., electronics and bicycles).  The bill applies only to new products.  SB 2660 adopts a familiar definition of PFAS: “any member of the class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom.”

Regulatory Structure

SB 2660 would require that MassDEP create two primary public lists of chemicals:

  1. Chemicals of concern in children’s products
  2. High priority chemicals

The chemicals of concern list would include a broad set of chemicals that may pose hazards in children’s products. Listing would trigger manufacturer reporting.

The high priority chemicals list would be a narrower subset of chemicals of concern, elevated based on evidence of exposure or other regulatory triggers.  Placement on this list would initiate stronger obligations, including substitution and, eventually, sale prohibitions.

Chemicals of Concern List & Requirements

A chemical may be placed on the chemicals of concern list if it is identified as:

  • A carcinogen or mutagen
  • Persistent or bio-accumulative and toxic (PBT)
  • An endocrine disruptor
  • A reproductive or developmental toxicant
  • A neurotoxicant
  • A respiratory or skin sensitizer
  • Any other chemical of equivalent concern

Within 180 days of listing, and biennially thereafter, manufacturers of children’s products containing a chemical of concern above de minimis levels would be required to notify MassDEP.  Notifications would be made available to the public, and would be required to include:

  • Chemical name
  • Product description
  • Brand, model, and UPC (if applicable)
  • Chemical function in the product
  • Amount of the chemical (ranges permitted)
  • Company and contact information
High Priority Chemicals List & Requirements

MassDEP would be allowed to elevate a chemical of concern to the high priority list if:

  • The chemical or its metabolites are found in humans through biomonitoring
  • The chemical is detected in household dust, indoor air, drinking water, or other home environments
  • The chemical is shown to release from a product, leading to likely exposure to children
  • The chemical or products containing it are restricted in another state

Manufacturers of children’s products containing a high priority chemical would be required to notify downstream sellers within 180 days of listing.

Within three years of listing, high priority chemicals would be required to be removed or substituted in children’s products that are (1) mouthable, (2) personal care products or cosmetics, or (3) intended for children under three.

Within five years, high priority chemicals would be prohibited in all children’s products unless preempted by federal law or if MassDEP determines that a ban would pose an unreasonable risk to public health, safety, or welfare.

Chemical Substitutions

SB 2660 also authorizes MassDEP to publish a safer alternatives list.  Manufacturers would be freely allowed substitute high priority chemicals with listed safer alternatives.

If a manufacturer chooses a substitute not on the safer alternatives list, MassDEP approval would be required.  Manufacturers would be required to explain how the product is less hazardous, and MassDEP may require submission of a hazard assessment.

Manufacturers may not replace a high priority chemical with a chemical of concern.

Exceptions and Extensions

SB 2660 includes several provisions to ease compliance:

  • MassDEP may grant temporary or permanent waivers from substitution requirements if exposure is not reasonably anticipated.
  • Manufacturers with 25 or fewer employees may apply for a two-year extension to the deadlines resulting from high priority listing.
  • MassDEP may not impose a lower allowable level than a federal consumer product safety standard unless it completes a rulemaking.
  • Additional exemptions may be established by regulation.
Enforcement and Other Provisions

MassDEP would have authority to adopt rules, test children’s products, and impose civil penalties of $5,000 per violation (or up to $10,000 for repeat violations).

Every three years, MassDEP would be required to publish a report on toxic chemicals in children’s products, including reporting outcomes and policy recommendations.

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Verdant Law closely monitors state-level chemical regulatory bills like SB 2660, including the rapidly expanding wave of PFAS-focused legislation.  Our team is ready to help your company assess potential compliance obligations, stay ahead of emerging requirements, and prepare for potential impacts across product lines and supply chains.

Connecticut PFAS in Products Notifications and Labeling Requirements Will Take Effect in 2026

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Manufacturers of many products containing intentionally added PFAS will soon be required to add PFAS labels and notify Connecticut’s Department of Energy and Environmental Protection (DEEP) before they can be made or sold in the state—some of the first such requirements in the country.

Connecticut’s PFAS in products legislation, codified at Conn. Gen. Stat. § 22a-903c, will also prohibit the use of intentionally added PFAS in these products beginning in 2028.

Like many other states, Connecticut broadly defines PFAS as “all members of the class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom.”  However, Connecticut’s legislation does not allow for exclusions for currently unavoidable uses, which is typically included in state-level PFAS legislation.

Labeling and Disclosure Requirements

Beginning January 1, 2026, PFAS disclosure requirements apply to outdoor apparel for severe wet conditions and “turnout” gear, which is used for firefighting.  Outdoor apparel for severe wet conditions must be accompanied by a disclosure with the statement “Made with PFAS chemicals,” including for online listings.  For turnout gear, sellers must provide written notice to the purchaser at the time of sale that indicates that the gear includes intentionally added PFAS and the reason for its addition.

Beginning July 1, 2026, products containing intentionally added PFAS in the following product categories must be labeled, using words or symbols approved by DEEP, to indicate that PFAS is present in the product:

  • Apparel (excluding including outdoor apparel for severe wet conditions)
  • Carpets or rugs
  • Cleaning products
  • Cookware
  • Cosmetic products
  • Dental floss
  • Fabric treatments
  • Children’s products
  • Menstruation products
  • Textile furnishings
  • Ski wax
  • Upholstered furniture

DEEP has released a draft order that would approve the words “Contains PFAS” or “Made with PFAS” as acceptable label language.  Labels must be durable and clearly visible prior to sale.  Manufacturers are responsible for labeling unless a wholesaler or retailer agrees to assume that responsibility.

Unlike New Mexico’s PFAS labeling requirements, finalized by regulation last month and discussed in a previous post, Connecticut does not currently offer an option to comply by following another state’s labeling scheme.

Notification Requirements

Starting July 1, 2026, manufacturers may not manufacture, sell, offer for sale, or distribute in Connecticut any product containing intentionally added PFAS in the categories listed above unless they provide prior written notice to DEEP.

Each notification must include:

  • A brief description of the product, including the product category and the function of PFAS in the product
  • All relevant CAS numbers, or, if unavailable, the molecular formulas and weights for all intentionally added PFAS
  • For each product category:
    • The amount of each PFAS or subgroup
    • The range of PFAS present by percentage weight
    • If no analytical method exists, the amount of total fluorine present
    • The purpose for which the PFAS is used
    • The manufacturer’s name, address, and contact information

Manufacturers must update the notification whenever any information changes. They may also report by product category or type rather than for each individual product.

DEEP has released a draft notification form for manufacturers, available here.

Sales Prohibitions

Beginning January 1, 2028, Connecticut will prohibit the sale or distribution of products in the categories listed above—as well as outdoor apparel for severe wet conditions and turnout gear—if they contain intentionally added PFAS.

The only exception is for cosmetic products containing “unavoidable trace quantity of PFAS that is attributable to impurities of natural or synthetic ingredients, the manufacturing process, storage or migration from packaging.”

Onne prohibition is already in effect: fertilizers intended for land application or soil amendment that contain biosolids or wastewater sludge with PFAS may not be used or sold in Connecticut.

More on Connecticut’s actions to address PFAS in consumer products, food packaging, and food serviceware can be found on DEEP’s website.

New Mexico Proposes First-Of-Its-Kind PFAS Labeling Requirements

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On October 8, 2025, the New Mexico Environment Department (NMED) proposed rules to implement the state’s PFAS Protection Act (HB 212).  In addition to phased-in prohibitions and reporting requirements, the proposal includes novel labeling requirements for all products containing intentionally added PFAS, with a compliance deadline of January 1, 2027.

HB 212 broadly defines PFAS as “a substance in a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom.”  This definition aligns with those adopted in other states—such as Maine and Minnesota—under their PFAS-in-products laws.

Labeling Requirements

Under the proposed rules, labels must:

  • Inform customers in both English and Spanish that the product contains intentionally added PFAS.
  • Use words and symbols approved by the department.
  • Be “likely to be seen, read and understood by an ordinary individual under customary conditions of purchase or use.”
  • Be “sufficiently durable to remain legible for the useful life of the product.”
  • Use a font size “no smaller than the largest font used for other consumer information on the product.”

For online or catalogue transactions, manufacturers or retailers must clearly disclose PFAS content to customers before purchase on sales literature, webpages, product specification sheets, and marketing materials, as applicable.  If product packaging obscures a label on the product itself, the packaging must be labeled in a compliant manner.

Example Labels

In a September 25, 2025, webinar, NMED shared preliminary label designs that would meet the proposed requirements, shown below.  The department emphasized that the graphics and language are not final.

Example labels for products and labels for product packaging

Exemptions and Special Cases

Used products are exempt from the proposed labeling requirements.  Manufacturers may also request a waiver for products in categories exempt from prohibition and reporting under HB 212—such as medical devices—if they can demonstrate that no PFAS will come into direct contact with consumers during intended use.

Complex durable goods and their components would be subject to alternative labeling requirements but would still need to inform customers of PFAS content.

If other states adopt PFAS labeling requirements, NMED’s proposal would allow manufacturers to comply by meeting comparable labeling rules in another state.

Opportunities for Engagement
  • Public comment period: Open through March 31, 2026.  Submit comments here.
  • Virtual public meeting: October 22, 2025, at 1pm MT (3pm ET).  Register here.
  • Public hearing: Expected around February 18, 2026, per NMED’s public involvement plan.
  • Final rule adoption: Expected by June 30, 2026.

For background on HB 212 and its broader PFAS restrictions, see our previous post.

EPA Adds PFAS to TRI List for 2026 Reporting

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On October 7, 2025, EPA announced the addition of a new PFAS to the Toxics Release Inventory (TRI): PFHxS-Na (CASRN 82382-12-5).  PFHxS-Na is a salt associated with the PFAS PFHxS (CASRN 335-46-4).

The addition takes effect January 1, 2026.  EPA will likely publish the formal amendment to the list of TRI-reportable chemicals in the Federal Register shortly.

Why Was This PFAS Added?

PFHxS-Na was automatically added to the TRI list after EPA finalized a toxicity value for PFHxS and its salts in a 2025 Integrated Risk Information System (IRIS) report.  Under the FY 2020 National Defense Authorization Act (NDAA), PFAS must be added to the TRI list when certain criteria—such as a finalized toxicity value—are met.

According to the announcement, the other PFAS identified in that IRIS assessment are already on the TRI list.

Implications for Reporting Entities

Supplier notifications for PFHxS-Na will be first required as of January 1, 2026, and reporting companies will be required to include PFHxS-Na in their Reporting Year 2026 reports, according to an EPA webpage.

With this update, EPA says that a total of 206 PFAS are now subject to TRI reporting.  The agency previously added nine PFAS to the TRI list in January 2025 for Reporting Year 2025 reports, which are due July 1, 2026.

In addition, EPA has proposed a rule to add 16 individual PFAS and 15 PFAS categories to the TRI list, while also formalizing the criteria for automatic PFAS additions.  The Trump administration’s Spring 2025 Unified Agenda indicates that EPA will finalize the rule in February 2026.

More on that rulemaking and EPA’s other TRI PFAS actions can be found in our TRI archive.

California Releases Preliminary List of Companies Covered by New Climate Disclosure Laws

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On September 24, 2025, the California Air Resources Board (CARB) released a preliminary list of covered entities under two new California climate disclosure laws that will require thousands of companies to report, with initial reporting deadlines beginning in 2026.

California’s SB 261 and SB 253, enacted in 2023, apply to companies formed under U.S. law that do business in California and have total annual revenues above certain thresholds:

  • SB 261 ($500 million threshold): Requires biennial disclosure of climate-related financial risk beginning January 1, 2026.
  • SB 253 ($1 billion threshold): Requires annual disclosure of scope 1 and 2 greenhouse gas emissions for the prior fiscal year beginning in 2026, and scope 3 emissions beginning in 2027. CARB has proposed a June 30, 2026, deadline for the first submission.

For each company, the preliminary list indicates whether reporting is required under both laws or only under SB 261.

SB 261 Reporting Guidance

The preliminary list follows CARB’s September 2 release of draft guidance on compliance with SB 261, which clarifies what information covered entities must include in their biennial reports.

Under the draft guidance, covered entities can choose between three reporting frameworks to meet disclosure requirements for four different areas: governance, strategy, risk management, and metrics and targets.  For each reporting area, the draft guidance outlines minimum disclosure requirements.

The draft guidance acknowledges that disclosures “will vary depending on the company, the discretion of the preparers, and the chosen reporting framework.”  CARB also states that a “guiding principle in preparation of these reports should be meeting the needs of the users of the biennial reports,” such as “investors and other stakeholders.”

Notably, CARB is not currently requiring disclosure of scope 1, 2, or 3 emissions for the initial reporting period.  In addition, companies may submit disclosures based on either calendar year or fiscal year data for their first biennial report.

EPA Proposes Adding Over 100 PFAS to TRI List

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Significantly more PFAS substances would be subject to Toxic Release Inventory (TRI) reporting under a proposed rule published by EPA on October 8, 2024.  The proposed rule would add 16 individual PFAS and 15 PFAS categories to the TRI list, which currently contains 196 PFAS.

The proposed additions would be made due to their potential human health effects, environmental effects, or both.  According to EPA, the 15 proposed category additions encompass over 100 individual PFAS.

The added PFAS would be subject to a reporting threshold of 100 pounds.  The manufacture, processing, and otherwise use of substances within a PFAS category would cumulatively count towards that category’s 100-pound threshold.

EPA is also proposing to add the proposed PFAS to the list of chemicals of special concern, which would make them ineligible for the de minimis exemption.  Under the de minimis exemption, facilities can disregard small concentrations of TRI chemicals in mixtures and trade name products when making threshold determinations.

EPA previously designated existing PFAS on the TRI list as chemicals of special concern in October 2023.  In that rulemaking, EPA argued that the move would “result in a more complete picture of the releases and waste management quantities for PFAS.”

The FY 2020 National Defense Authorization Act (NDAA) instructed EPA to add certain PFAS to the TRI list with a 100-pound reporting threshold.  “Congress’ use of this low reporting threshold demonstrates a concern for even relatively small quantities of these PFAS,” EPA said.

EPA was required to evaluate some of the proposed PFAS additions for possible inclusion by section 7321 of the NDAA.  However, the NDAA did not specify what the threshold should be for those additions.  In the proposed rule, EPA defended its proposed 100-pound threshold, saying that it would “maintain consistency for all chemicals added to TRI pursuant to the NDAA.”

The NDAA also instructs EPA to add PFAS automatically when certain conditions are met.  In the proposed rule, EPA clarified its interpretation of those conditions, which include when EPA “finalizes a toxicity value” for a PFAS.

Finally, EPA is proposing that it add related PFAS (like an acid and its associated salts) under the NDAA as a category going forward. The proposed rule would also consolidate certain existing individual PFAS on the list into categories.

Comments on the proposed rule are due November 7, 2024.

EPA Finalizes TRI PFAS Reporting Rule

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On October 31, EPA published its final rule, Changes to Reporting Requirements for PFAS and to Supplier Notifications for Chemicals of Special Concern which modifies the requirements for TRI reporting. These new requirements take effect November 30, 2023, and will apply for the reporting year beginning January 1, 2024; first reports with these requirements will be due July 1, 2025. The rule puts forth two significant changes to the current reporting requirements.

The first change to the reporting requirements is that all PFAS presently subject to TRI reporting will be added to the TRI list of Chemicals of Special Concern (“COSC List”). In addition, in the future, any PFAS added to the TRI list of toxic chemicals will automatically be added to the COSC list without the Agency having to go through a separate rulemaking process as was previously required. Furthermore, all PFAS on the COSC list will be held to the same reporting standard as all other chemicals on the COSC list. This means that all PFAS will be excluded from the de minimis exemption, which had excused quantities of PFAS present in mixtures at less than 1 percent (0.1 for PFOA) from contributing to reporting thresholds. In addition, facilities will no longer be able to report these substances on Form A (the less extensive of the reporting forms) and will not be able to report quantities using ranges. Under the requirements previously in place, Form A could be used for PFAS reporting if each of the following criteria has been met:

  • The reportable chemical substance is not a PBT.
  • The reportable chemical substance was not manufactured, processed, or otherwise used in excess of 1,000,000 lbs.
  • If the total reportable amount of the chemical substance released did not exceed 500 lbs.

Under the new requirements, no one will be able to report PFAS manufacture, processing, use, and releases on Form A. However, Form A can still be used to meet the reporting requirements for PFAS during the 2023 reporting year; beginning in 2024, PFAS will need to be reported using the more extensive Form R.

The second change to the TRI reporting requirements eliminates the de minimis exemption under the supplier notification requirements for all COSC, including PFAS. This change also goes into effect for the 2024 reporting year. The de minimis exemption for supplier notification meant that raw material suppliers were not required to notify their customers of the presence of PFAS in mixtures below specific concentrations (1 percent for non-carcinogens and 0.1 percent for carcinogens or, in the present case, 1 percent for PFAS and 0.1 percent for PFOA). Eliminating the de minimis exemption for reporting will add notification requirements on suppliers of products containing COSC and include such information on their SDSs. Consequentially, facilities will have more information about their processing, use, and/or release of PFAS, and downstream manufacturers will likely have more information to report to EPA for TRI.