Connecticut's PFAS Regulation CT SB 292

Connecticut has enacted one of the most expansive PFAS product laws in the United States — and it’s not a future-dated concept law. It’s live, phased, and enforceable.

With Connecticut Public Act No. 24-59 (formerly Substitute Senate Bill No. 292), the state is moving from PFAS disclosure to outright product bans across a wide range of consumer goods.

The law took effect October 1, 2024, with mandatory disclosure, labeling, and full prohibitions rolling out through January 1, 2028.

This is not a labeling exercise. It is a product-level market access law.

What Connecticut Is Regulating under PFAS

Public Act No. 24-59 applies to consumer products that contain intentionally added PFAS. The scope is deliberately broad and targets products with high consumer exposure or environmental release risk.

Covered Product Categories

The law applies to the following product groups:

• Apparel
• Carpets and rugs
• Cleaning products, including air care products
• Cookware
• Cosmetic products
• Dental floss
• Fabric treatments
• Children’s products
• Menstruation products
• Textile furnishings
• Ski wax
• Upholstered furniture

If your product falls into one of these categories and contains intentionally added PFAS, it is in scope.

Connecticut PFAS Compliance Timeline (Critical Dates)

October 1, 2024 — Law Effective

Enforcement authority begins. Reporting and compliance planning should already be underway.

January 1, 2026 — Targeted Disclosure Requirements

From this date:

1. Outdoor apparel for severe wet conditions Any new product containing PFAS must clearly disclose — on the product and any online listing:

“Made with PFAS chemicals”

2. Turnout gear Products containing intentionally added PFAS must include written notice at the time of sale, stating:

• PFAS is present, and
• the reason PFAS was intentionally added

These are mandatory disclosures — not optional labels.

July 1, 2026 — Notification + Labeling Gate

On and after July 1, 2026, manufacturers may not manufacture, sell, offer for sale, or distribute covered products containing intentionally added PFAS unless BOTH conditions are met:

1. Prior written notification is submitted to the Connecticut Department of Energy and Environmental Protection (DEEP), and
2. The product is labeled using DEEP-approved PFAS language

Notification alone is not sufficient.

Required DEEP Notification Content

Manufacturers must provide:

• A brief product description

• CAS Registry Numbers for all intentionally added PFAS (or molecular formula and molecular weight where CAS is unavailable)

• For each product category:

  • amount of each PFAS
  • PFAS percent-by-weight range
  • total fluorine amount if no analytical method exists

• Purpose of PFAS use

• Manufacturer identity and contact information

Submissions may be made by product category or type, but must be updated whenever information changes or upon DEEP request.

January 1, 2028 — Full PFAS Product Ban

From January 1, 2028 onward:

No person may manufacture, sell, offer for sale, or distribute covered products in Connecticut if they contain intentionally added PFAS, unless a statutory exemption applies.

This is a hard ban, not a reporting alternative.

PFAS Labeling Requirements in Connecticut

Connecticut requires explicit, consumer-visible PFAS labeling during the transition period.

Labeling Rules

Labels must:

• be visible before purchase
• clearly state that PFAS is intentionally added using DEEP-approved wording
• remain legible for the product’s useful life

DEEP has issued an official list of approved phrases, including variations such as:

• “Contains PFAS”
• “Made with PFAS”
• “Made with PFAS chemicals”
• “This product contains PFAS”

Using non-approved language increases enforcement risk.

PFAS Exemptions and Special Cases

Public Act No. 24-59 includes defined exemptions, including:

• Products where federal law requires PFAS
• Used products
• FDA-regulated medical devices
• Products made with ≥ 85 percent recycled content
• Products manufactured before applicable prohibition dates
• Replacement parts for legacy products
• Products regulated under Conn. Gen. Stat. §§ 22a-903a or 22a-255i

Exemptions are not automatic — documentation is required.

Enforcement, Reporting, and Oversight

The Commissioner of DEEP enforces the law and may:

• request certificates of compliance
• require supporting documentation
• assess administrative fees
• coordinate with other state agencies

The law also authorizes a multijurisdictional PFAS clearinghouse, enabling data sharing across states on:

• PFAS-containing products
• granted exemptions
• compliance records

This signals future cross-state enforcement alignment.

What This Means for Manufacturers

Formulation Risk

PFAS often enter products through:

• coatings
• treatments
• additives
• supplier sub-materials

“Yes/No PFAS” declarations are no longer defensible.

Data Risk

Connecticut explicitly requires:

• chemical identifiers
• quantity ranges
• functional purpose justification

Without material-level data, compliance breaks quickly.

Market Risk

Connecticut joins states like Washington, New York, and California in moving from PFAS disclosure to prohibition.

State-by-state firefighting does not scale.

What Companies Should Do Now

1. Map products against Connecticut’s covered categories
2. Identify intentionally added PFAS at material and substance level
3. Prepare DEEP-ready disclosure datasets
4. Align labeling language to DEEP approvals
5. Build a reformulation roadmap well before 2028

Waiting until enforcement letters arrive is already too late.

Final Takeaway

Connecticut’s PFAS law is not incremental. It is structural.

Manufacturers that treat PFAS as a short-term reporting issue will lose market access. Manufacturers that invest in material-level PFAS intelligence will scale across states.