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US Regulations

US PFAS Laws: Maine, Minnesota & Multi-State Rules

There is no comprehensive federal PFAS ban in the United States — yet. Instead, a rapidly growing patchwork of state laws is creating one of the most administratively complex compliance landscapes in the country. Maine and Minnesota have passed the most sweeping PFAS restrictions. California, New York, Vermont, Washington, Colorado, and more than a dozen other states have enacted product-specific PFAS bans covering food packaging, cosmetics, textiles, carpets, firefighting foam, and children's products. For a manufacturer selling into multiple US states, the question is no longer "does my product contain PFAS?" but "which state's threshold applies to which product category?"

PFAS (per- and polyfluoroalkyl substances) — often called "forever chemicals" — are a class of approximately 12,000 synthetic chemicals used for their water, grease, and stain-resistant properties. The EPA has designated PFOA and PFOS as hazardous substances under CERCLA, and the agency has set enforceable drinking water standards for six PFAS compounds. But for product manufacturers, the compliance obligation today comes primarily from state laws — and the two most sweeping are Maine's LD 1503 and Minnesota's Amara's Law.

NY Fashion Act: Supply Chain Due Diligence Law

New York is the fashion capital of the United States, and the New York Fashion Sustainability and Social Accountability Act (originally introduced in 2021 as Senate Bill S7428 / Assembly Bill A8352 and reintroduced in 2023) is the most aggressive state-level fashion regulation proposed in the country. If passed, it would require fashion brands and retailers doing business in New York with more than $100 million in global revenue to map their supply chains, disclose environmental and social impacts, and set binding targets for improvement.

The NY Fashion Act is modeled in part on the French Duty of Vigilance Law (LdV) and the EU's CSDDD — but specifically tailored to the fashion, footwear, and apparel industry. On the Sustalium platform, we are already seeing fashion brands begin to structure their supply chain data in anticipation of the legislation, because the mapping and disclosure requirements mirror what their European operations are already doing under CSRD and CSDDD.

FDA MoCRA: Cosmetic Compliance & Registration

Before the Modernization of Cosmetics Regulation Act (MoCRA) was signed into law in December 2022, cosmetic manufacturers could legally sell products in the US without ever registering with the FDA or listing a single product ingredient. The FDA had no authority to recall unsafe cosmetics, no mandatory adverse event reporting system for cosmetics, and no requirement that manufacturers substantiate product safety. MoCRA changed all of that in a single legislative package — the most significant overhaul of US cosmetic regulation since the Federal Food, Drug, and Cosmetic Act of 1938.

MoCRA imposes mandatory facility registration, product listing, safety substantiation, adverse event reporting, and — for the first time — gives the FDA mandatory recall authority over cosmetics. On the Sustalium platform, the MoCRA-related compliance activity we see most is cosmetic brands and contract manufacturers reconciling their ingredient lists with the FDA's product listing format — because the FDA's electronic submission portal requires structured ingredient data, and most brands' internal records are not yet structured to match.

CA TPPA: Toxics in Packaging Compliance Guide

The Toxics in Packaging Clearinghouse (TPCH) — a coalition of 19 US states — regularly screens packaging for restricted heavy metals and publishes its findings. In its most recent screening report, the TPCH found that packaging from several major brands and retailers contained cadmium and lead above the 100 ppm threshold, with the highest concentrations appearing in inks, pigments, and plastic colorants rather than the base packaging material itself. This matters because the enforcement target is shifting: it is no longer enough to certify the substrate. Every component layer — inks, coatings, adhesives — must independently comply.

The California Toxics in Packaging Prevention Act (TPPA) — codified at Health and Safety Code §§ 25214.11–25214.26 — prohibits the intentional use of cadmium, lead, mercury, and hexavalent chromium in any packaging or packaging component sold or distributed in California. Nineteen other states have adopted identical legislation through the TPCH model. On the Sustalium platform, we see TPPA compliance appearing most frequently in packaging declarations for consumer goods, cosmetics, and food products — sectors where California distribution is essentially guaranteed and the multi-state nature of the requirement means companies must comply across a patchwork of state laws with a single, consistent Certificate of Compliance.

US Lacey Act: Import Declaration for Plant Products

In 2023 and 2024, US Customs and Border Protection stepped up seizures of imported wood products with incomplete or inaccurate Lacey Act declarations — including multiple container-loads of hardwood flooring and furniture from Southeast Asia. CBP's enforcement focus has shifted from high-profile criminal prosecutions to routine port-level verification: if the species, country of harvest, or quantity on your PPQ 505 form does not match the shipment, the goods are detained, and the importer of record bears the cost of storage, re-export, or destruction.

The US Lacey Act (16 U.S.C. §§ 3371–3378) was originally enacted in 1900 to combat wildlife trafficking. The 2008 amendment extended it to plants and plant products, creating a mandatory import declaration regime that covers an enormous range of goods — from raw timber to finished furniture, paper, and musical instruments. On the Sustalium platform, we see Lacey Act declarations becoming a more frequent request in the furniture and construction materials supply chains, as US retailers strengthen their import compliance programs.

FDA Food Contact Material: Compliance Guide

In 2023, the FDA issued warning letters to multiple manufacturers of food contact articles — including a major manufacturer of reusable plastic food containers — for failing to provide adequate documentation that their food contact substances were approved for their intended use. The common thread in all the letters: the companies had test data showing their products were safe, but they could not produce a properly structured Declaration of Compliance that mapped each substance in the material to its regulatory clearance. The FDA's position was unambiguous: data without a properly structured declaration is not compliance documentation.

Under the Federal Food, Drug, and Cosmetic Act (FFDCA) and 21 CFR Parts 170–199, any material intended to contact food during manufacturing, packaging, storage, or preparation must be approved by the FDA or be Generally Recognized as Safe (GRAS). The manufacturer or supplier issues a Declaration of Compliance (DoC) — a self-declared document that certifies the material meets FDA regulatory requirements. On the Sustalium platform, food-contact declarations are one of the most cross-referenced document types we see: a food packaging supplier issues a Declaration of Compliance to its downstream customer, who must then present it to their own buyer or retailer audit.

US vs. EU Food Contact: One Product, Two Frameworks

A food packaging product sold in both the United States and the European Union must satisfy two separate food contact regulatory regimes — and neither accepts the other's documentation. The FDA Declaration of Compliance cites 21 CFR regulations and Food Contact Notifications. The EU Declaration of Compliance cites Regulation (EC) 1935/2004 and material-specific measures like the Plastics Regulation (EU) 10/2011. The migration testing is similar but the test conditions, simulants, and limits differ. And a Declaration of Compliance valid in one market is not valid in the other.

This guide compares the two systems, identifies the key operational differences, and explains how to build dual-market food contact compliance without duplicating every test.

US Apparel Compliance: Flammability, Labeling & Rules

Apparel compliance in the United States is deceptively fragmented. The federal requirements are relatively minimal — a flammability standard, a fiber content label, and a country of origin marking. But state-level obligations — California's Proposition 65, the emerging NY Fashion Act, PFAS restrictions across multiple states, and packaging heavy metal rules — add layers of compliance that many apparel importers discover only at the point of enforcement.

This guide maps every US compliance requirement for apparel and textiles, from the federal baseline through the state-level obligations that increasingly define market access.

US Toys: CPC, ASTM F963 & State Requirements

Toys are the most heavily regulated consumer product category in the United States — and the compliance path is fundamentally different from general consumer goods. The key difference is that toys require a Children's Product Certificate (CPC) , not the General Certificate of Conformity (GCC) that covers adult products. The CPC demands third-party testing at a CPSC-accepted laboratory, additional chemical restrictions beyond what applies to general consumer goods, and specific labeling requirements — including a tracking label on every product.

This guide covers every compliance requirement for toys sold in the US, from federal testing standards to state-level chemical warnings, and compares the US framework to the EU Toy Safety Directive for brands selling in both markets.

Selling Cosmetics in the US and EU: MoCRA vs. CPSR

A cosmetic brand selling in both the United States and the European Union must comply with two regulatory frameworks that are structurally similar but operationally distinct — and neither framework accepts the other's documentation. The US system, modernized in 2022 by MoCRA, emphasizes manufacturer self-declaration of safety. The EU system, established under the Cosmetic Products Regulation (EC) 1223/2009, requires a qualified safety assessor to prepare a formal Cosmetic Product Safety Report (CPSR) and mandates notification to the EU's Cosmetic Product Notification Portal (CPNP) before the product reaches the market.

For brands selling in both markets, the compliance cost is additive — you need both a MoCRA safety substantiation and an EU CPSR. But the ingredient data and toxicological assessments that support one can inform the other, and building both in parallel from the same product data is significantly more efficient than treating them as separate compliance projects.