New York State PFAS Ban Law (S5648): The 2025 Effective Date for Textile and Apparel Regulation and Its Phased Exemption
ENFORCEMENT TIMELINE
Effective January 1, 2025 (extreme-weather gear granted a grace period until January 1, 2028)
Overview
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.
Enforcement Timeline
January 1, 2025: S5648 takes effect (same effective date as California's AB 1817)
2028: End of the phased exemption period for severe-weather outdoor apparel, subject to consumer disclosure
Business Impact
Apparel manufacturers, importers, and retailers selling into New York must eliminate intentionally added PFAS from apparel products, with the exception of severe-weather outdoor apparel granted a phased exemption through 2028 subject to consumer disclosure, and should note the close structural parallel to California's AB 1817 when designing a unified multi-state compliance approach.
