U.S. Vermont Passed Bill S.25 to Update PFAS Bans on Consumer Products
| Targeted audience |
U.S. domestic manufacturers, distributor; U.S. importers and upstream suppliers |
| Products concerned |
Consumer products |
| Key industries concerned with this insight |
Cookware, Juvenile Products, Upholstered Furniture, Food packaging |
| Application date |
January 1, 2026 |
| Main content or requirements |
U.S. Vermont updates PFAS bans on consumer products. |
| Reference |
https://legislature.vermont.gov/bill/status/2024/S.25 |
On May 30, 2024, the Governor of U.S. Vermont State signed Bill S.25 to amend PFAS restriction on consumer product.
The following products containing intentionally added PFAS chemicals shall not be manufactured, sold, offered for sale, distributed for sale or distributed for use in Vermont after the relevant effective date:
| Products |
Requirements |
Effective date |
| Cosmetic or menstrual product |
Prohibited if intentionally added |
January 1, 2026 |
- Aftermarket stain and water-resistant treatments for rugs or carpets
- Cookware
- Incontinency protection product
- Juvenile products
- Ski wax or related tuning products
|
Prohibited if intentionally added |
January 1, 2026 |
| Artificial turf |
Prohibited if intentionally added, or the addition of PFAS was known or reasonably ascertainable to be from manufacturing or processing of the product |
January 1, 2026 |
| Residential rug or carpet |
Prohibited if added |
January 1, 2026 |
| Textile or textile article |
Prohibited if
- intentionally added and have a functional or technical effect in the product, or
- ≥ 100 ppm as measured in total organic fluorine (TOF)
|
January 1, 2026 |
| Textile or textile article |
Prohibited if
- intentionally added and have a functional or technical effect in the product, or
- ≥ 50 ppm as measured in total organic fluorine (TOF)
|
July 1, 2027 |
| Class B firefighting foam |
- Prohibited to be discharged or used for training or testing if intentionally added
- Prohibited to be manufactured, sold, offered for sale, distributed for sale or use if intentionally added
|
January 1, 2026 |
| Personal protective equipment |
Provide written notice to purchaser at the time of sale if PPE contains PFAS |
January 1, 2026 |
| Food packaging |
Prohibited if intentionally added |
January 1, 2026 |
In addition, for food packaging, in addition to the PFAS requirements mentioned above, there are also Bisphenols and Ortho-phthalates prohibiting requirements. The overall requirements for food packaging are as follows:
| Products |
Substance |
Requirements |
Effective date |
| Food packaging |
PFAS |
Prohibited if intentionally added |
January 1, 2026 |
| Food packaging |
Bisphenols |
Rules may be adopted to prohibit such intentionally added chemical, if safer alternatives are available |
Two years after rules have been adopted |
| Food packaging |
Ortho-phthalates |
Prohibited if intentionally added |
January 1, 2026 |
Meanwhile, Vermont Laws 18 V.S.A. Chapter 33 (PFAS in firefighting agents and equipment), 18 V.S.A. Chapter 33A (chemicals of concern in food packaging), 18 V.S.A. Chapter 33B (PFAS in rugs, carpets, and aftermarket stain and water resistant treatments), and 18 V.S.A. Chapter 33C (PFAS in ski wax) will be repealed on January 1, 2026.
Note:
- ”Cookware” means durable houseware items used to prepare, dispense, or store food, foodstuffs, or beverages and that are intended for direct food contact, including pots, pans, skillets, grills, baking sheets, baking molds, trays, bowls, and cooking utensils.
- ”Juvenile product” means a product designed or marketed for use by infants and children under 12 years of age:
- including a baby or toddler foam pillow; bassinet; bedside sleeper; booster seat; changing pad; infant bouncer; infant carrier; infant seat; infant sleep positioner; infant swing; infant travel bed; infant walker; nap cot; nursing pad; nursing pillow; play mat; playpen; play yard; polyurethane foam mat, pad, or pillow; portable foam nap mat; portable infant sleeper; portable hook-in chair; soft-sided portable crib; stroller; toddler mattress; and disposable, single-use diaper; and
- excluding a children’s electronic product, such as a personal computer, audio and video equipment, calculator, wireless phone, game console, handheld device incorporating a video screen, or any associated peripheral such as a mouse, keyboard, power supply unit, or power cord; a medical device; or an adult mattress.
- ”Textile articles” means textile goods of a type customarily and ordinarily used in households and businesses, and includes apparel, accessories, handbags, backpacks, draperies, shower curtains, furnishings, upholstery, bedding, towels, napkins, and table cloths. “Textile articles” does not include:
- A vehicle, as defined in 1 U.S.C. § 4, or its component parts;
- A vessel, as defined in 1 U.S.C. § 3, or its component parts;
- An aircraft, as defined in 49 U.S.C. § 40102(a)(6), or its component parts;
- Filtration media and filter products used in industrial applications, including chemical or pharmaceutical manufacturing and environmental control technologies;
- Textile articles used for laboratory analysis and testing; and
- Rugs or carpets.
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