USA: Vermont further expands PFAS ban
June 2025 - Electrical and electronics, hardlines, softlines, toys and children's products
The Vermont Governor has signed the bill H.2381 to further expand the scope of perfluoroalkyl and polyfluoroalkyl substances (PFAS) in firefighting gear, dental floss, cleaning products, and fluorine-treated containers. This amendment builds on the current PFAS ban in Vermont. It aims to phase out and finally prohibit the manufacture, sales or distribution for sales of certain products containing intentionally added PFAS.
Back in May 2024, Vermont’s wide-sweeping ban on PFAS in cosmetics, menstrual products, artificial turf, incontinence products and cookware became law2, most requirements would take effect in 2026.
In addition to expanding the scope, the bill provides further clarity on the definition of “intentionally added PFAS” including the use of processing agents, mold release agents or intermediates. Moreover, the amendment mandates that manufacturers provide certificates of compliance to the Attorney General upon request and prohibits the use of fluorine-treated containers for certain products. The fluorine-treated containers and any consumer products in such containers would be banned on 1 January 2032.
Here is a brief summary of the Vermont PFAS ban:
| Scope | Requirement | Effective date |
| Uniform worn by firefighters underneath personal protective equipment (See Remark 1) | Manufacturers are required to provide written notice if the station wear contains PFAS and the notice must be retained by the manufacturers and purchasers for at least 3 years. |
1 July 2025 Note: This is required before the ban of PFAS in apparel effective on 1 January 2026 |
|
Prohibited if it contains intentionally added PFAS |
1 January 2026 |
|
Prohibited if it contains intentionally added PFAS |
1 July 2027 |
|
Prohibited if it contains intentionally added PFAS |
1 July 2028 |
|
Manufacturers are required to provide written notice if the PPE contains PFAS and the notice must be retained by the manufacturers and purchasers for at least 3 years |
1 January 2026 |
| Prohibited if it contains intentionally added PFAS |
1 July 2029 |
|
|
Manufacturers shall provide written notice to the purchaser at the time of sale, if the respirator or respirator protection equipment contains PFAS. The notice must be retained by the manufacturers and purchasers for at least 3 years |
1 July 2029 |
| Prohibited if it contains intentionally added PFAS |
1 July 2032 |
Remark 1:
- The regulated PFAS for textiles is defined as the PFAS which is intentionally added to a product and has a functional or technical effect in the product or the presence of total organic fluorine at or above 100 ppm (this will be decreased to 50 ppm from 1 July 2027);
- The requirement of outdoor apparel for severe wet conditions will apply from 1 July 2028.
Remark 2:
- The fluorine treated containers used in the products above marked with * would be banned (effective 1 July 2027). Starting from 1 January 2032, the ban will be extended to any fluorine treated containers or any consumer products in such containers.
References:
[2] TÜV SÜD E-ssential Vol. 3, June 2024
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