Textile and Apparel PFAS Ban (AB 1817): Exempted Categories and Phased Grace Periods
ENFORCEMENT TIMELINE
Effective January 1, 2025 (extreme-weather gear granted a grace period until January 1, 2028)
Overview
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.
Enforcement Timeline
September 29, 2022: AB 1817 is signed into law (same day as AB 2771)
January 1, 2025: AB 1817 takes effect for most textile articles
January 1, 2028: Grace period ends for outdoor apparel intended for severe wet-weather conditions
Business Impact
Apparel and textile manufacturers, importers, and retailers selling into California must eliminate intentionally added PFAS from new textile products, with the exception of outdoor apparel for severe wet-weather use (permitted through January 1, 2028 with consumer disclosure) and certain PPE. As with AB 2771, the absence of a dedicated enforcement mechanism means companies should anticipate compliance risk primarily through private litigation rather than regulatory enforcement actions.