Important Year-End Developments In PFAS State Law: Minnesota, New Mexico, And Connecticut

States continue to advance restrictions and disclosure requirements for products that contain per- and polyfluoroalkyl substances (PFAS). State regulators are increasingly using rulemaking to implement and better define the scope of statutory PFAS-in-products obligations, particularly with respect to:

• Product labeling and disclosure
• Manufacturer reporting
• Definitions of "intentionally added PFAS"
• Exemptions and phase-in periods

Recent developments in Minnesota, New Mexico, and Connecticut reflect the differing regulatory approaches. This Advisory highlights recent PFAS actions in these three states, identifies key dates and upcoming deadlines, and offers practical considerations for product manufacturers. It is important to note, however, that a number of other states have already codified PFAS regulations, and many other states are considering similar actions.