ARTICLE
2 October 2025

Comments Due October 8, 2025, On Connecticut's Draft PFAS Reporting Form For Manufacturers And Draft Order Regarding Labeling

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Bergeson & Campbell

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Bergeson & Campbell, P.C. is a Washington D.C. law firm focusing on chemical product approval and regulation, product defense, and associated business issues. The Acta Group, B&C's scientific and regulatory consulting affiliate provides strategic, comprehensive support for global chemical registration, regulation, and sustained compliance. Together, we help companies that make and use chemicals commercialize their products, maintain compliance, and gain competitive advantage as they market their products globally.
Beginning July 1, 2026, Connecticut will prohibit the manufacture, sale, and distribution of certain consumer products that contain intentionally added per- and polyfluoroalkyl substances (PFAS)...
United States Connecticut Energy and Natural Resources

Beginning July 1, 2026, Connecticut will prohibit the manufacture, sale, and distribution of certain consumer products that contain intentionally added per- and polyfluoroalkyl substances (PFAS) unless the manufacturer provides prior notification to the Connecticut Department of Energy and Environmental Protection (DEEP) and labels these products. The consumer products are apparel; carpets or rugs; cleaning products; cookware; cosmetic products; dental floss; fabric treatments; children's products; menstruation products; textile furnishings; ski wax; or upholstered furniture. Under the statute, the notification must include:

  • A brief description of the product, including the product category and the function of PFAS in the product;
  • All relevant Chemical Abstracts Service Registry Numbers® (CAS RN®) or, if no such number is applicable, the molecular formulas and weights for all PFAS intentionally added to the product; and
  • For each product category: the amount of each PFAS or subgroups in each category; the range of PFAS in the product category by percent weight; if no analytical method exists, the amount of total fluorine present in the product category; the purpose for which the PFAS is used in the product; and the name and address of the manufacturer, and the name, address and phone number of a contact person for the manufacturer.

The statute states that, beginning July 1, 2026, these products must be labeled. If one of these products is a component of another product, the product that contains the component must be labeled. All labels must be clearly visible prior to sale and inform the purchaser that PFAS is present in the product. Labels affixed to products must be constructed of materials that are sufficiently durable to remain legible for the useful life of the product. Manufacturers must apply any required product and package labels unless the wholesaler or retailer agrees with the manufacturer to accept responsibility for such application.

DEEP has released a draft reporting form for manufacturers and a draft order regarding the labeling requirements. Comments are due October 8, 2025, to DEEP.MMCAPlanning@ct.gov.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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