We use cookies to give you the best possible experience while you browse through our website. By pursuing the use of our website you implicitly agree to the usage of cookies on this site. Learn More - Privacy Policy

Tue Jul 16 2024 | 2 min read

Table of Contents

Rhode Island is considering joining the growing group of U.S. states that restrict intentionally added PFAS in consumer products — but it has not yet enacted a comprehensive consumer PFAS ban.

Rhode Island House Bill 7356 is a proposed bill that would phase out PFAS in specified consumer products if enacted. Much of the confusion around Rhode Island PFAS regulation comes from treating this proposal as if it were already law.

It is not.

This page explains what H7356 proposes, what product categories are in scope, and what is not enforceable today.

What Is Rhode Island H7356?

H7356 is a proposed consumer-product PFAS restriction bill introduced in the Rhode Island General Assembly.

If enacted, the bill would:

  • prohibit the manufacture, sale, and distribution of covered products containing intentionally added PFAS,
  • establish phased effective dates for different product categories,
  • require manufacturer certifications and notifications,
  • and authorize enforcement by the Rhode Island Department of Environmental Management (DEM).

As of now, H7356 has not been enacted, and none of its compliance obligations are in force.

Proposed Product Categories Covered by H7356

The bill defines a set of “covered products”, which include:

  • artificial turf
  • carpets and rugs
  • cookware
  • cosmetic products
  • fabric treatments
  • juvenile products
  • menstrual products
  • ski wax
  • textile articles (including apparel)

These definitions are proposed statutory language, not current regulatory requirements.

How H7356 Defines “Intentionally Added PFAS”

Under the bill, PFAS are considered “intentionally added” when:

  • they are deliberately introduced during manufacturing to achieve a specific function or characteristic, or
  • they result from the intentional addition of another chemical that degrades into PFAS.

This definition mirrors language used in other state PFAS proposals and is meant to distinguish functional use from trace contamination.

Proposed Prohibitions and Timelines (If Enacted)

H7356 outlines a phased prohibition structure, which would apply only if the bill becomes law.

General Consumer Product Ban (Proposed)

  • January 1, 2027 Manufacture, sale, and distribution of covered products containing intentionally added PFAS would be prohibited.

Additional Product-Specific Provisions (Proposed)

  • January 1, 2029

    • Artificial turf containing intentionally added PFAS would be prohibited.
    • Outdoor apparel for severe wet conditions could remain on the market only if labeled “Made with PFAS chemicals.”

These dates are proposed, not binding.

Manufacturer Obligations (Proposed)

If enacted, H7356 would require manufacturers to:

  • certify compliance for covered products,
  • notify retailers when products are prohibited from sale,
  • and provide certificates of compliance upon request by DEM.

These obligations do not apply today.

Enforcement and Penalties (Proposed)

The bill proposes civil penalties of:

  • up to $1,000 for a first violation, and
  • up to $5,000 for subsequent violations.

Enforcement authority would rest with the Rhode Island Department of Environmental Management, but only after enactment.

Important Clarification: Firefighting Foam

H7356 is often incorrectly described as a firefighting foam ban.

It is not.

Rhode Island already regulates PFAS in firefighting foam under separate, earlier legislation. H7356 focuses on consumer products, not emergency-response foams.

Blending these regimes leads to compliance errors.

Exemptions in the Proposed Bill

H7356 includes proposed exemptions for:

  • unavoidable trace quantities of PFAS in cosmetics (e.g., impurities or packaging migration),
  • used or second-hand products.

These exemptions would only apply if the bill is enacted.

What Is Enforceable in Rhode Island Today

As of now:

  • Rhode Island does regulate PFAS in firefighting foam under existing law.
  • Rhode Island does not have a comprehensive consumer PFAS product ban.
  • H7356 represents policy direction, not current compliance obligation.

What H7356 Signals for Manufacturers

Even though H7356 is not law, it signals that:

  • Rhode Island is aligning with states like Maine, Connecticut, and Minnesota on consumer PFAS policy,
  • future PFAS regulation is likely to be product-category-specific,
  • manufacturers without material-level PFAS visibility will struggle to respond quickly if enacted.

Final Takeaway

Rhode Island H7356 is a proposed consumer PFAS ban, not enacted law.

It does not currently prohibit PFAS in consumer products, impose certification duties, or trigger compliance deadlines. But it clearly signals the direction of travel.

Companies that treat H7356 as irrelevant will be reactive. Companies that prepare now will adapt with minimal disruption if the bill advances.

Speak to Our Compliance Experts