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Illinois has quietly become one of the most consequential U.S. states for PFAS compliance.
What started as a focused effort to control PFAS releases from firefighting foam has expanded into a multi-layered regulatory framework covering emergency response materials, consumer products, and firefighter protective equipment. For manufacturers selling into Illinois, PFAS compliance is no longer theoretical — it is category-specific, enforceable, and phased.
Illinois’ PFAS Framework at a Glance
Illinois PFAS regulation now operates across three distinct but connected areas:
- Class B firefighting foam
- Select consumer products
- Firefighter clothing and protective equipment
Each area has its own timelines, obligations, and enforcement mechanisms. Treating Illinois as a “single PFAS law” is a common — and costly — mistake.
PFAS Reduction Act: Firefighting Foam Controls
Illinois Public Act 102-0290
Illinois’ PFAS journey began with the PFAS Reduction Act, which targets Class B firefighting foam containing intentionally added PFAS — historically one of the largest sources of PFAS environmental contamination.
Use restrictions already in force
Since January 1, 2022, PFAS-containing Class B foam may not be used for training or testing except under tightly controlled conditions. Where testing is permitted, facilities must implement containment, treatment, and disposal measures and train employees on PFAS hazards. Emergency firefighting use remains allowed.
Manufacture and sale phase-out
As of January 1, 2025, manufacturers may no longer knowingly manufacture, sell, or distribute PFAS-containing Class B firefighting foam in Illinois.
Certain operators — including refineries, chemical plants, and fuel storage facilities — may extend compliance until January 1, 2027, but only by formally notifying the Office of the State Fire Marshal. This is a temporary accommodation, not a permanent exemption.
Release reporting and disposal
Any discharge or release of PFAS-containing Class B foam must be reported to the Illinois Emergency Management Agency within 48 hours. Reports must include the time, location, estimated quantity, cause, containment actions, and responsible entity.
The law also strictly prohibits flushing or draining PFAS foam into waterways, storm drains, or sewers. Expired foam must be disposed of using approved methods within 90 days of expiration.
Expansion to Consumer Products (2025 Amendment)
Illinois HB 2516
In August 2025, Illinois significantly expanded its PFAS framework beyond firefighting foam.
Beginning January 1, 2026, Illinois will prohibit the manufacture, sale, or distribution of covered consumer products that contain intentionally added PFAS.
Affected product categories include:
- cookware
- cosmetics
- dental floss
- juvenile products
- menstrual products
- intimate apparel
- food packaging and food-contact products
This expansion places Illinois alongside states such as Maine and Connecticut, shifting from PFAS management toward product-level bans.
Firefighter Protective Equipment and PPE Restrictions
Illinois HB 2409
Illinois has also addressed PFAS exposure risks faced by firefighters.
Starting January 1, 2026, firefighter protective clothing or equipment that contains PFAS must carry a written notice at the time of sale. One year later, on January 1, 2027, the manufacture and sale of PFAS-containing firefighter protective clothing will be prohibited, unless a statutory exception applies.
This applies even where PFAS are used for performance reasons, reflecting Illinois’ growing emphasis on occupational exposure.
What This Means for Manufacturers
Illinois no longer regulates PFAS in isolation. It regulates where PFAS are used, why they are used, and who is exposed.
For manufacturers, the risk is no longer limited to firefighting foam suppliers. Consumer brands, PPE manufacturers, and importers must now understand PFAS at the material and component level, not just through high-level declarations.
“PFAS-free” claims must be defensible. Unsupported marketing language creates enforcement exposure in a state that is actively expanding PFAS controls.
What Companies Should Be Doing Now
Manufacturers selling into Illinois should:
- map products by regulatory category (foam, consumer goods, PPE)
- identify intentionally added PFAS at the material level
- align reformulation and sourcing timelines to 2026 and 2027 deadlines
- update disposal, reporting, and incident-response procedures
- monitor Illinois rulemaking and enforcement guidance as it evolves
Waiting until enforcement actions begin is already too late.
Final Takeaway
Illinois PFAS regulation is no longer a single statute — it is a stacked compliance system.
Companies that still view PFAS as a niche firefighting-foam issue will miss consumer product bans and PPE restrictions that are already locked into law. For national manufacturers, Illinois now belongs in the same compliance tier as Maine and Connecticut.