Under Connecticut’s new law — Connecticut General Statutes §22a-903c — manufacturers, distributors, and sellers of certain consumer products containing perfluoroalkyl or polyfluoroalkyl chemicals (PFAS), commonly known as “forever chemicals,” are now, as of July 1, subject to new labeling and reporting requirements.

The law will be enforced and overseen by Connecticut’s Department of Energy and Environmental Protection (DEEP).

The law’s first phase, which began this past July, imposes reporting and labeling requirements in advance of the second phase: a complete ban on the sale and distribution of certain PFAS-containing products beginning in 2028. With this law, Connecticut joins the growing number of states that are regulating the sale of consumer products containing PFAS.

Connecticut’s law applies to 12 categories of consumer products, including apparel, carpets and rugs, cleaning products, cookware, cosmetic products, dental floss, fabric treatments, children’s products, menstruation products, textile furnishings, ski wax, and upholstered furniture. Products within these categories are referred to as “covered products.”

Manufacturers, sellers, and distributors may manufacture, sell, offer for sale, or distribute covered products containing intentionally added PFAS only if the products bear a clearly visible label informing prospective purchasers that PFAS are present in the product.

In addition, the law requires manufacturers of covered products containing intentionally added PFAS to provide prior notice to DEEP by submitting a PFAS Reporting Form and paying an $800 registration fee. The notice must include, among other information, a description of what category the product falls into, the function of PFAS in the product, the amount of PFAS present, and the reason PFAS is used. DEEP may request revisions to a submission, and manufacturers must revise and resubmit their notifications as required.

Connecticut’s law is also notable because it requires companies to evaluate whether their products can be reformulated without intentionally added PFAS. This differs from New Jersey’s PFAS law (previously covered earlier this year), which does not impose a similar reformulation requirement.

The reformulation requirement is intended to encourage companies to assess alternatives before Connecticut’s forthcoming ban on covered products containing intentionally added PFAS. Effective January 1, 2028, no person may manufacture, sell, offer for sale, or distribute for sale any covered product that contains intentionally added PFAS in Connecticut.

This 2028 ban represents the final phase of Connecticut’s PFAS law. Before then, however, affected companies must comply with the law’s reporting and labeling requirements.

Companies impacted by this law should be aware of the law, identify affected products, determine whether PFAS have been intentionally added, prepare the required Connecticut notices and labels, and begin planning for the broader sales prohibition that takes effect in 2028.