Naomie Halioua
Co-founder & CRO, AI Research
Connecticut’s PFAS label takes effect 1 July — and it won’t satisfy New Mexico’s, which starts six months later
From 1 July 2026, Connecticut bars the sale of 12 everyday product categories — apparel, cookware, cosmetics, children’s products among them — if they contain intentionally added PFAS, unless the label carries state-approved wording, under Conn. Gen. Stat. § 22a-903c. Most coverage reads this as “a state bans forever chemicals.” It isn’t, yet: the actual sales ban is 18 months away, on 1 January 2028. What takes effect now is a per-SKU chemical-disclosure and labeling regime — and New Mexico’s own PFAS rule, six months behind it, requires a different label entirely.
What Connecticut’s law actually requires, and when
Conn. Gen. Stat. § 22a-903c, created by Public Act No. 24-59 in 2024, phases in over three stages. From 1 July 2026, a manufacturer may still sell a covered product containing intentionally added PFAS in Connecticut — but only if it first gave the Department of Energy and Environmental Protection (DEEP) prior written notice (a product description, the type, amount and function of the PFAS, and any related analytical data) and the product carries an approved label. On 1 December 2025, DEEP Commissioner Katherine Dykes issued an order under Gen. Stat. § 22a-6 fixing the approved wording: “Contains PFAS,” “Made with PFAS,” “Made with PFAS chemicals,” “Made with intentionally added PFAS,” “This product contains PFAS chemicals,” or an ingredient-list disclosure — with a route for manufacturers to petition DEEP for alternative language.
Three nuances that separate signal from noise
01
Disclosure now, ban later
1 July 2026 is a notify-and-label deadline. The outright sales prohibition on these categories doesn’t bite until 1 January 2028.
02
Text-based, not symbol-based
Connecticut’s approved labels are written phrases fixed by a DEEP order — there is no required icon or pictogram.
03
Twelve categories, not “PFAS products”
The law names specific categories — apparel, cookware, cosmetics, juvenile products among them — not PFAS-containing goods generally.
1 Dec 2025
DEEP Commissioner Katherine Dykes orders the approved PFAS label phrases under Gen. Stat. § 22a-6.
1 Jul 2026
Notification-to-DEEP and approved-label requirement takes effect for 12 covered product categories sold in Connecticut.
1 Jan 2027
New Mexico’s own PFAS labeling requirement takes effect — a printed Erlenmeyer-flask symbol plus the word “PFAS,” not text phrases.
1 Jan 2028
Connecticut’s outright sales prohibition on the 12 categories takes effect for products with intentionally added PFAS, regardless of labeling.
Twelve categories, one written notice, six approved phrases
The law names twelve covered categories: apparel, carpets or rugs, cleaning products, cookware, cosmetic products, dental floss, fabric treatments, juvenile products, menstruation products, textile furnishings, ski wax, and upholstered furniture. A brand selling any of these into Connecticut with intentionally added PFAS must, before 1 July 2026, have already sent DEEP a written notice covering the product, the PFAS type, amount and function, and supporting analytical data — then affix one of the Commissioner’s approved phrases, durable enough to stay legible for the product’s useful life.
12
covered product categories under § 22a-903c, from apparel to upholstered furniture
6
DEEP-approved label phrases — or a manufacturer can petition for its own wording
18 mo
between the labeling deadline (Jul 2026) and the outright sales ban (Jan 2028)
The real subject: the same PFAS fact, two incompatible labels
Six months after Connecticut’s deadline, New Mexico’s own PFAS Protection Act rule takes effect on 1 January 2027 — and it requires something structurally different: a printed Erlenmeyer-flask symbol paired with the word “PFAS,” not a choice of approved sentences. New Mexico’s labeling scope is also wider than its own sales restrictions, reaching some products that are otherwise exempt from the ban or reporting rules. A brand’s underlying fact — “this SKU contains intentionally added PFAS, of this type, at this concentration” — does not change between Hartford and Santa Fe. The label it has to produce does, on two different clocks, in two different formats, decided by two different agencies.
That is a product-data problem before it is a labeling-design one. A brand needs, per SKU: whether PFAS was intentionally added, its type and concentration, which of the twelve Connecticut categories or the New Mexico equivalents the SKU falls under, and which state-specific label format and effective date apply where it ships. Static spreadsheets built for one state’s wording break the moment a second state defines the same disclosure differently — which is exactly what just happened.
Two ways to read 1 July
The narrow read
Connecticut becomes the latest state to crack down on “forever chemicals.” File it under one more ingredient restriction.
The structural read
A single product fact — intentionally added PFAS, per SKU — now has to be filed, formatted and labeled differently in every state that regulates it, on staggered clocks. That mapping only holds if the product data behind it is kept current, state by state, as each one moves.
Sources
- Justia — Connecticut General Statutes § 22a-903c, Intentionally added PFAS in consumer products (official code text)
- Connecticut DEEP — Order Pursuant to General Statutes § 22a-6, Commissioner Katherine Dykes (approved PFAS label phrases)
- National Law Review — Connecticut Order Lists Approved Phrases for July 1, 2026, Labeling Requirement
- Shipman & Goodwin LLP — Connecticut Provides Required PFAS Wording for Product Labels on Certain Consumer Goods
- Bergeson & Campbell, P.C. — New Mexico’s Final PFAS Rule Includes January 1, 2027, Labeling Requirement
- New Mexico Environment Department — New Mexico approves labeling of PFAS in consumer products
Frequently asked questions
What exactly changes in Connecticut on 1 July 2026?
Under Conn. Gen. Stat. § 22a-903c, manufacturers of 12 covered product categories — apparel, carpets or rugs, cleaning products, cookware, cosmetic products, dental floss, fabric treatments, juvenile products, menstruation products, textile furnishings, ski wax and upholstered furniture — containing intentionally added PFAS must, from 1 July 2026, have already given the Department of Energy and Environmental Protection (DEEP) prior written notice and carry one of DEEP's approved label phrases. It is not yet a sales ban.
Is Connecticut banning PFAS-containing products on 1 July 2026?
No. 1 July 2026 is the notification-and-labeling deadline. The outright prohibition on selling these 12 categories with intentionally added PFAS, regardless of labeling, takes effect later, on 1 January 2028 — an 18-month gap during which disclosure and labeling, not reformulation, is the immediate obligation.
Does Connecticut's approved PFAS label also satisfy New Mexico's requirement?
No. Connecticut's DEEP-approved labels are written phrases (e.g. "Contains PFAS") fixed by a December 2025 DEEP order. New Mexico's PFAS Protection Act rule, taking effect 1 January 2027, requires a different format — a printed Erlenmeyer-flask symbol paired with the word "PFAS" — with a broader scope than its own sales restrictions. A brand shipping the same SKU to both states needs two separate, state-specific labels.
Sources & references
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