Connecticut's PFAS Regulation CT SB 292

Connecticut has taken a significant step towards reducing PFAS in consumer products with the enactment of Public Act No. 24-59 (Substitute Senate Bill No. 292), effective October 2024.

Products affected by PFAS regulation in Connecticut

The new law targets a wide range of consumer products that often contain intentionally added PFAS.

Here's a comprehensive list of products included under the regulation:

• Apparel: Clothing items intended for daily wear or formal occasions, excluding personal protective equipment and military/aerospace gear.
• Carpets and Rugs: Fabric products intended as floor coverings.
• Cleaning Products: Items used for domestic, commercial, or institutional cleaning, including air care products and automotive maintenance products.
• Cookware: Durable houseware items used to prepare, dispense, or store food.
• Cosmetic Products: Articles intended for application to the human body for cleansing or beautifying.
• Dental Floss: Products used for cleaning between teeth.
• Fabric Treatments: Substances applied to fabrics to give characteristics like stain or water resistance.
• Children's Products: Items designed for use by children under twelve years old, including mattresses, highchairs, and strollers.
• Menstruation Products: Items used to collect menstrual and vaginal discharge.
• Textile Furnishings: Textile goods used in households and businesses, excluding items for vehicles and industrial applications.
• Ski Wax: Lubricants applied to the bottom of skis and snowboards.
• Upholstered Furniture: Furniture designed for sitting, resting, or reclining.

PFAS Compliance Deadlines and Requirements in Connecticut

By July 1, 2026, manufacturers must stop producing, selling, or distributing the listed products containing intentionally added PFAS unless they provide a written notification to the Department of Energy and Environmental Protection (DEEP).

This notification must include:

• A brief description of the product.

• The relevant chemical abstract service registry numbers or, if not applicable, the molecular formulas and weights for all PFAS intentionally added to the product.

• For each product category: the amount of each PFAS, the range of PFAS by percent weight, and if no analytical method exists, the amount of total fluorine present.

• The purpose for which the PFAS is used in the product.

• Manufacturer details and contact information.

• Manufacturers may supply this information for a category or type of product rather than each individual product. They must update and revise information whenever there is a change or upon the department's request.

• From January 1, 2026, New outdoor apparel for severe wet conditions must include a disclosure statement indicating it contains PFAS. Similarly, any turnout gear containing PFAS must have written notice provided to purchasers at the time of sale.

• From January 1, 2028, forward, no person shall manufacture, sell, offer for sale, or distribute any of the listed products if they contain intentionally added PFAS.

PFAS Labeling Requirements in Connecticut

Products containing PFAS must be clearly labeled to inform consumers. Labels should:

• Be visible before sale.
• Indicate the presence of PFAS using approved words or symbols.
• Be durable enough to remain legible for the product's useful life.
• Manufacturers are responsible for applying these labels unless an agreement is made with wholesalers or retailers to accept this responsibility.

PFAS Exemptions and Special Cases in Connecticut

The law includes several exemptions, such as:

• Products for which federal law requires PFAS presence.
• Used products.
• Medical devices regulated by the FDA.
• Products made with at least 85% recycled content.
• Products manufactured before the prohibition dates.
• Replacement parts for products made before the prohibition dates.

PFAS Enforcement and Compliance in Connecticut

The Commissioner of Energy and Environmental Protection will enforce the law, potentially coordinating with other commissioners. Manufacturers must furnish certificates of compliance upon request and may face fees to cover administrative costs. The law also allows for the establishment of a multijurisdictional clearinghouse to assist in compliance and maintain a database of products containing PFAS and exemptions granted.

PFAS Reporting Requirements for Manufacturers in Connecticut

Manufacturers will need to navigate new reporting requirements to ensure compliance with Public Act No. 24-59.

These requirements include:

• Detailed Notifications: Manufacturers must provide detailed notifications to DEEP, outlining the presence of PFAS in their products. This includes descriptions of the product, chemical details, purposes for PFAS use, and manufacturer contact information.

• Ongoing Updates: Any changes to the product composition or PFAS content must be reported promptly. This requires robust internal tracking and documentation systems to ensure accuracy and timeliness.

• Labeling Compliance: Manufacturers must ensure that all products containing PFAS are appropriately labeled. This involves coordinating with suppliers, retailers, and possibly re-engineering packaging to meet the durable labeling requirements.

For more information on PFAS regulations Reporting and Recordkeeping under TSCA Section 8(a) 7 Download our eBook.