U.S. California and State-Level Regulatory System

California's Climate Corporate Data Accountability Act (SB 253) is an exceptionally stringent climate disclosure rule that legally requires companies of a certain size doing business in California to calculate and publicly disclose their greenhouse gas (GHG) emissions—Scope 1, Scope 2, and Scope 3—across their entire supply chain. The law applies to all companies, public or private, that do business in California and have total global annual revenues exceeding $1 billion, directly capturing large global manufacturers, general trading companies, and automakers with California-based subsidiaries. Its most notable feature is that it clearly mandates third-party-assured Scope 3 disclosure—covering raw material sourcing, product use, and disposal—ahead of comparable disclosure rules in other countries or at the U.S. federal level.

California's Climate-Related Financial Risk Act (SB 261) requires companies of a certain size doing business in California to identify climate-related financial risks and report on measures to mitigate them. The law applies to companies with total annual revenues of $500 million or more doing business in the state, and requires biennial disclosure aligned with international frameworks such as the TCFD. Its purpose is to improve transparency across supply chains and provide information to investors; because non-compliance is subject to penalties, companies need to urgently establish climate-related governance and data collection systems.

California's Safe Drinking Water and Toxic Enforcement Act (Proposition 65), enacted in 1986. It requires clear warnings before selling, in the state, products that may expose consumers to any of more than 900 chemicals the state has identified as causing cancer or reproductive harm.

AB 2771 (the PFAS-Free Cosmetics Act) took effect January 1, 2025, prohibiting the manufacture, sale, and distribution of cosmetics containing intentionally added PFAS in California. Whereas AB 2762 (the Toxic-Free Cosmetics Act, enacted in 2020) covered only 13 specific PFAS substances, AB 2771 represents a substantial expansion in scope by covering the entire class of PFAS chemicals (over 12,000 substances). A notable practical feature of the law is that it contains no explicit enforcement agency or penalty provisions. As a result, enforcement occurs primarily through civil litigation under California's Unfair Competition Law (UCL) and false advertising statutes, with litigation risk from consumer groups and competitors functioning as the de facto deterrent mechanism. Because California is one of the world's largest cosmetics markets, many manufacturers have been compelled to revise product formulations on a nationwide or global basis in response to this state-level regulation.

AB 1817 prohibits the manufacture, distribution, sale, and offering for sale of new textile articles containing intentionally added PFAS in California, effective January 1, 2025. Outdoor apparel intended for severe wet-weather conditions is granted a three-year grace period, remaining permissible for sale until January 1, 2028, subject to a consumer disclosure requirement. Certain personal protective equipment (PPE) is also exempted from the ban. Enacted on the same day as AB 2771 (cosmetics), the two laws share the common feature of lacking an explicit enforcement agency or penalty provisions. Because California represents a major market for the outdoor apparel industry, the law has prompted a nationwide reassessment of supply chains—particularly among material manufacturers that use PFAS in water-repellent treatments.

California's SB 54 (Plastic Pollution Prevention and Packaging Producer Responsibility Act) imposes comprehensive Extended Producer Responsibility (EPR) obligations on producers of single-use plastic packaging and plastic foodware. It mandates a 25% reduction in the volume of single-use plastic packaging sold by 2032 and requires that all packaging sold in the state be 100% recyclable or compostable.

California's AB 1200 bans intentionally added PFAS in paper-based food-contact packaging and requires disclosure labeling—on the product itself and on the company website—when cookware (frying pans, pots, etc.) contains designated chemicals on the food-contact surface, such as Proposition 65-listed substances or PFAS.

California's AB 1628 is a bill that, to prevent microplastic fibers shed from synthetic textiles from entering oceans and waterways, phases in a requirement that all residential and commercial washing machines sold in the state come standard with a high-precision filtration filter (microfiber filter) that captures microplastic particles.

California's SB 343 (Truth in Recycling Act) significantly tightens the conditions under which products and packaging may display a recyclability mark (the chasing arrows symbol) or claim recyclability. It bans, as "false environmental claims" (greenwashing), the display of a recycling mark on resins or materials that are not actually being collected, sorted, and recycled at facilities within the state (e.g., accessible to at least 60% of the state's population).

Minnesota's Amara's Law is one of the strictest PFAS phase-out laws in the nation. It phases in bans on the sale of products containing intentionally added PFAS and, by 2032, bans the use of PFAS in virtually all products except for "currently unavoidable uses." It includes early bans and pre-sale reporting requirements for specific product categories (carpets and rugs, cleaning products, cookware, cosmetics, apparel, etc.).

New York State has enacted a law prohibiting intentionally added PFAS in paper- and fiber-based food-contact packaging, and enforcement auditing by state authorities has intensified following the law's implementation. As with other states (including Maine and Washington), food packaging tends to be one of the earliest-effective categories among state PFAS regulations, and New York's approach follows this broader trend.

Colorado's HB 22-1345 (enacted 2022) prohibited the sale and distribution of carpets and rugs, fabric treatments, and oil and gas products containing intentionally added PFAS, effective January 1, 2024, and expanded the ban to cosmetics and indoor textile furnishings and upholstered furniture effective January 1, 2025. On May 1, 2024, Colorado enacted SB 24-081 (the PFAS Chemicals Protection Act), further expanding the scope of regulation established under HB 22-1345. The ban on intentionally added PFAS in cookware takes effect January 1, 2026, with commercial food equipment following on January 1, 2028. The law additionally adds certain cleaning products, outdoor apparel, textile products, menstrual products, ski wax, and dental floss to the list of banned intentionally-added-PFAS items. Pharmaceuticals, medical devices, biologics, veterinary pesticides, and their packaging that are federally regulated are exempted.

Connecticut's PFAS product regulation law (Public Act 24-115) adopts a phased transitional approach. Beginning January 1, 2026, a wide range of product categories—including apparel, turnout gear, carpets and rugs, cleaning products, cookware, cosmetics, dental floss, fabric treatments, children's products, menstrual products, textile furnishings, ski wax, upholstered furniture, and outdoor apparel for severe weather conditions—enter a phase in which manufacture, sale, offering for sale, and distribution of products containing intentionally added PFAS is permitted only subject to notification to the state Department of Energy and Environmental Protection (DEEP) and consumer-facing disclosure and labeling. Beginning January 1, 2028, the conditional sale phase (based on disclosure and notice) ends for all of the above product categories, and manufacture, sale, offering for sale, and distribution of products containing intentionally added PFAS becomes unconditionally prohibited. Separately, the use and sale of PFAS-containing biosolids (sewage sludge) as a soil amendment has already been prohibited since the law's effective date of October 1, 2024.

Maine enacted, in 2021, a pioneering regulatory framework requiring comprehensive advance notification for all products containing intentionally added PFAS (38 M.R.S. §1614). However, due to practical difficulties in implementing this general notification requirement, a 2024 statutory amendment (Public Law 2023, c.630, effective April 2024) repealed the general notification obligation that had originally been scheduled to take effect January 1, 2025, and replaced it with a narrower reporting regime limited to product categories granted a "Currently Unavoidable Use" (CUU) designation. The sales prohibition schedule is staggered by product category: carpets/rugs and fabric treatments have been banned since January 1, 2023; beginning January 1, 2026, the ban expands to cleaning products, cookware, cosmetics, dental floss, children's products, menstrual products, textile products (with certain exceptions), ski wax, and upholstered furniture; beginning January 1, 2029, the ban is scheduled to expand further to artificial turf and severe-weather outdoor apparel (unless PFAS use is disclosed); and by January 1, 2032, all products containing intentionally added PFAS are, in principle, prohibited (except for uses granted a CUU designation). The regulations governing the CUU designation process itself (amended Chapter 90) took effect October 7, 2025, and the Department of Environmental Protection (DEP) plans to continue reviewing additional CUU applications from spring 2026 onward.

Oregon's SB 543 (enacted 2023, effective January 1, 2025) covers three distinct areas of regulation. First, it prohibits food vendors from providing or selling prepared food in expanded polystyrene foam (commonly known as Styrofoam) containers. Second, it prohibits the sale and distribution of expanded polystyrene foam containers and packing peanuts themselves. Third, it prohibits the sale and distribution of foodware containers containing intentionally added PFAS. The definition of foodware containers is broad, covering bowls, plates, cups, lids, clamshell containers, and similar items used to serve or store prepared food, including takeout and leftovers. Food vendors in violation face fines of up to $100 per day, while businesses that sell or distribute PFAS-containing containers, foam containers, or packing peanuts face fines of up to $500 per day. Expanded polystyrene used as protective packaging during storage or transport, or as a food transport tray, is exempted from the ban.

New York's S5648 (apparel PFAS ban law) prohibited, effective January 1, 2025, the sale within the state of apparel products containing intentionally added PFAS. The law took effect on the same date as California's AB 1817, making New York and California the two leading early adopters of PFAS regulation in the textile and apparel sector. As with California's framework, outdoor apparel intended for severe weather conditions is granted a phased exemption through 2028, conditioned on consumer disclosure—a design closely paralleling California's approach.

Colorado's HB 22-1355 (Producer Responsibility Program for Worldwide Recycling) is an Extended Producer Responsibility (EPR) law that requires producers of packaging and printed paper to fund and build a statewide recycling program. It is a state-level EPR system following California, Oregon, and Maine.

Washington State's Safer Products for Washington is one of the nation's most advanced and comprehensive state-level environmental laws for managing and eliminating chemicals of concern in consumer products. The bill (SB 5135) was enacted in 2019, and after the state Department of Ecology conducted phased assessments and developed regulatory rules, the "first round of regulatory actions" (Cycle 1 rules) formally took effect on July 1, 2023. This established a legal requirement of either an "intentional-addition ban" or "detailed content reporting" for priority hazardous chemicals — PFAS, organophosphate flame retardants, phthalates, bisphenols, and alkylphenols — in covered household and consumer products. 1. Phthalate restrictions: Restrictions on phthalates in vinyl flooring and plastic components of consumer products. 2. PFAS (per- and polyfluoroalkyl substance) restrictions: Ban on intentionally added PFAS in household carpets, rugs, and stain- and water-resistant treated apparel and household goods. 3. Alkylphenol ethoxylate (APEO) restrictions: Ban on APEOs in laundry detergents and cleaning products.

New York State's Buy Climate Friendly Purchasing Act is a dedicated law that prioritizes and mandates the procurement of low-carbon, "climate-friendly" materials for all public construction and infrastructure projects commissioned by state government agencies. Aligned with the federal Buy Clean initiative, the law legally requires suppliers of major construction materials — such as concrete (cement), steel, and flat glass — to state government to submit Environmental Product Declarations (EPDs) certifying the environmental impact of their products, with state-set emissions thresholds phased in between 2025 and 2026.

A law applicable to companies that do business in or sell products or services into California, requiring them to publicly disclose on their corporate website detailed information about the purchase and sale of voluntary carbon credits (offsets), along with the quantitative basis for climate-related marketing claims such as "carbon neutral," "net zero," or "low carbon." Its purpose is to prevent opaque use of offsets and greenwashing by companies.