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.
The State PFAS Landscape: Two Tiers¶
State PFAS laws fall into two categories:
Tier 1: Comprehensive PFAS Reporting and Bans¶
These states require broad PFAS disclosure and are phasing in outright bans on PFAS in most product categories:
| State | Law | Reporting Deadline | Ban Target |
|---|---|---|---|
| Maine | LD 1503 | Jan 2023 (ongoing) | 2030 (with exceptions for unavoidable use) |
| Minnesota | HF 2310 (Amara's Law) | Jan 2026 | 2032 (with 11 product categories banned by 2025) |
Tier 2: Product-Specific PFAS Restrictions¶
These states have enacted PFAS restrictions for specific product categories:
| State | Restricted Categories |
|---|---|
| California | Food packaging, cosmetics, textiles, children's products, firefighting foam |
| New York | Food packaging, apparel, carpets, firefighting foam, cosmetics |
| Vermont | Food packaging, firefighting foam, residential carpets |
| Washington | Food packaging, firefighting foam, cosmetics |
| Colorado | Firefighting foam, food packaging, cosmetics, oil and gas products |
| Connecticut | Food packaging, firefighting foam |
| Maryland | Food packaging, firefighting foam |
Maine LD 1503: The Most Aggressive PFAS Law in the US¶
Maine's "An Act to Stop Perfluoroalkyl and Polyfluoroalkyl Substances Pollution" (LD 1503) takes the broadest approach of any US state:
- Reporting requirement: Any manufacturer of products containing intentionally added PFAS sold in Maine must report to the Maine Department of Environmental Protection (DEP). The reporting includes the product category, a description of the PFAS compounds used, the purpose of PFAS in the product, and the amount of PFAS present.
- Ban: Effective January 1, 2030, any product containing intentionally added PFAS may not be sold in Maine — unless the DEP determines that the use of PFAS is "currently unavoidable." This exception is narrow, and the burden of proof is on the manufacturer.
- Enforcement: Failure to report can result in fines and prohibition of sale. The DEP has the authority to require manufacturers to provide documentation demonstrating the absence of PFAS.
Minnesota Amara's Law (HF 2310)¶
Minnesota's PFAS legislation, passed in 2023 and known as "Amara's Law," phases in restrictions on an accelerated timeline:
- Phase 1 (2025): Immediate ban on PFAS in 11 product categories: carpets and rugs, cleaning products, cookware, cosmetics, dental floss, fabric treatments, children's products, menstrual products, textile furnishings, ski wax, and upholstered furniture. This is the most aggressive phase-in timeline of any US state.
- Phase 2 (2026): All manufacturers of products containing intentionally added PFAS must report to the Minnesota Pollution Control Agency (MPCA). Reporting requirements are similar to Maine's — product category, PFAS identity and purpose, amount, and manufacturer contact information.
- Phase 3 (2032): Prohibition on PFAS in all products, with an unavoidable-use exception process similar to Maine's.
The Federal Context¶
While states are driving PFAS regulation for products, the EPA has been active on the environmental side:
- Drinking water standards: In April 2024, the EPA issued the first enforceable National Primary Drinking Water Regulation for six PFAS compounds.
- CERCLA designation: In April 2024, the EPA designated PFOA and PFOS as hazardous substances under CERCLA, which triggers reporting requirements for releases of these compounds and allows the EPA to pursue cleanup cost recovery.
- TSCA reporting: The EPA's PFAS reporting rule under TSCA Section 8(a)(7) requires any entity that has manufactured or imported PFAS since 2011 to report production volumes, uses, and environmental releases.
These federal actions do not directly regulate PFAS in finished products — but they increase the overall regulatory pressure and create supply chain data expectations that flow down to manufacturers.
Compliance Strategy for Multi-State PFAS Requirements¶
The patchwork of state PFAS laws creates a specific compliance challenge: a product that is compliant in California may not be compliant in Minnesota, and the reporting requirements differ by state. Practical steps:
1. Audit Your Product Portfolio for PFAS¶
Map every product SKU against known PFAS use cases. Common applications in manufacturing include: - Water-resistant coatings on textiles and apparel - Grease-proof coatings on food packaging - Non-stick coatings on cookware - Stain-resistant treatments on carpets and upholstery - Cosmetics with water-resistant or long-wear properties - Industrial lubricants and mold-release agents
2. Collect PFAS Supplier Declarations¶
Request structured PFAS declarations from every material and chemical supplier. A simple "PFAS-free" statement is insufficient — you need a declaration that identifies whether PFAS is intentionally added, which specific PFAS compounds are used, and in what concentration. This mirrors the information required by state reporting laws.
3. Map State Requirements to Each Product¶
For each SKU sold in the US, determine which states' PFAS laws apply. A product sold nationally is effectively subject to the strictest applicable law — because it is impractical to isolate distribution channels by state. This typically means that Maine's reporting requirements and Minnesota's Phase 1 ban categories become the de facto national compliance standard for many manufacturers.
How Sustalium Supports PFAS Compliance¶
The core challenge of multi-state PFAS compliance is data management: knowing which PFAS compounds are in which products at which concentrations, tracking which state laws apply, and maintaining supplier declarations in an audit-ready format.
Sustalium's chemical compliance platform supports PFAS documentation:
- PFAS Declaration Builder: Enter your product's material composition and PFAS status for each component. Sustalium generates a structured PFAS declaration that covers intentional use, specific compound identification, purpose of use, and concentration — satisfying the reporting formats required by Maine DEP and Minnesota MPCA.
- Supplier PFAS Data Collection: A supplier-facing portal where your material and chemical suppliers can input their PFAS declarations directly into a structured format — replacing PDF-based declarations that are inconsistent and non-comparable.
- Multi-State Compliance Tracking: Sustalium maps your product data against the PFAS requirements of each state where your products are sold, flagging products that fall into restricted categories or exceed reporting thresholds in any jurisdiction.
- Integrated Chemical Compliance: PFAS declarations sit alongside your REACH SVHC declarations, RoHS compliance data, Proposition 65 warnings, and TSCA reporting — creating a single chemical compliance hub that covers US, EU, and UK requirements from the same product data.
Get Ahead of the Multi-State PFAS Compliance Patchwork
With Maine's broad reporting requirements already in force and Minnesota's 2026 reporting deadline approaching, PFAS disclosure is not optional. Structure your PFAS data once and comply across all states.
With Sustalium, build your PFAS compliance declaration for just €10 per document.
Frequently Asked Questions¶
Do state PFAS laws apply to products manufactured outside the US?
Yes. The state laws apply to products sold or distributed in the state, regardless of where they are manufactured. A product manufactured in China and sold in Maine or Minnesota is subject to the same reporting requirements and ban deadlines as a domestically manufactured product.
What is the threshold for PFAS reporting in Maine and Minnesota?
Both states trigger reporting for products containing "intentionally added" PFAS — meaning there is no minimum concentration threshold for the reporting requirement. If PFAS is intentionally added for any functional purpose, the product must be reported, regardless of the amount. Incidental contamination is generally not subject to the intentional-use reporting requirement, but the burden is on the manufacturer to demonstrate that the presence is incidental.
How do US state PFAS laws compare to EU PFAS restrictions?
The EU is moving toward a comprehensive PFAS restriction under REACH, with ECHA evaluating a proposal to ban the entire class of PFAS substances across all uses. US state laws are more fragmented — some states focus on specific product categories, while Maine and Minnesota are moving toward broad bans. The EU's approach is more centralized, but the direction of regulation is the same: PFAS as a class is being phased out. The key difference for manufacturers is that EU compliance involves a single regulatory process, while US compliance requires tracking up to 15 different state regimes.
Last updated: July 22, 2026