Connecticut PFAS Product Regulation Law (Public Act 24-115): The January 2026 Disclosure/Notice Phase and the Transition to a Full 2028 Ban
ENFORCEMENT TIMELINE
Labeling and notice obligations effective January 1, 2026; full product ban effective January 1, 2028
Overview
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.
Enforcement Timeline
October 1, 2024: Public Act 24-115 takes effect; ban on PFAS-containing biosolids as a soil amendment begins immediately
January 1, 2026: Conditional sale phase begins for a broad range of product categories, requiring DEEP notification and consumer disclosure
January 1, 2028: Unconditional ban on intentionally added PFAS takes effect across all covered product categories
Business Impact
Manufacturers and distributors of the broad range of product categories covered by Public Act 24-115 must plan for two distinct compliance milestones: the January 1, 2026 transition into a conditional sale regime requiring DEEP notification and consumer disclosure, and the January 1, 2028 transition to an unconditional ban across the same product categories, with the intervening two-year window serving as the practical compliance runway for reformulation or phase-out.