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.