Connecticut Issues Guidance on PFAS Labeling and Notification Requirements

Last month, the Connecticut Department of Energy and Environmental Protection (DEEP) released guidance on the state’s PFAS product restrictions, including the labeling and notification requirements that took effect for twelve product categories on July 1, 2026.

The guidance clarifies that the notification and labeling requirements apply to products manufactured before the July 1 effective date, despite the statute’s exemption for products manufactured prior to an applicable prohibition. This is because the notification and labeling requirements “are requirements, not prohibitions,” DEEP states.

“Manufacturers may direct retailers to apply a label for products that are already in their inventory,” the guidance adds.

DEEP also states that it is not issuing compliance extensions. “If your product is out of compliance, please submit the notification and begin labeling products immediately,” it says.

Other provisions of the guidance clarify that:

  • For online sales, the label disclosure must be provided on the same webpage as the product, without requiring the consumer to click to another webpage;
  • Labels may be affixed to the packaging of a product or the product itself, so long as they are clearly visible prior to sale;
  • Products subject to federal labeling requirements, such as those arising under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), are not subject to the state’s labeling requirement; and
  • Because “no person” may sell noncompliant products, retailers are required to stop offering any product that DEEP determines to be noncompliant.

The guidance is posted on DEEP’s PFAS in products webpage.

Covered Product Categories

The twelve product categories subject to the July 1, 2026, labeling and notification deadline are:

  • Apparel (excluding 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

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. Outdoor apparel for severe wet conditions and turnout gear are subject to slightly different disclosure requirements, which took effect January 1, 2026.

DEEP has approved multiple label disclosure options. Most recently, it approved a symbol consisting of an outline of an Erlenmeyer flask with the word “PFAS” inside—the same design required under New Mexico’s near-universal PFAS labeling requirement, which a federal court has preliminarily blocked.

More information on the labeling and notification requirements can be found in a previous post.