USA · Consumer Products · Chemicals

The American Legislative Exchange Council (ALEC) published the PFAS Model Policy Act, providing a legislative framework that states may use to regulate consumer products containing intentionally added PFAS. The model outlines product prohibitions, manufacturer reporting obligations, testing provisions, enforcement mechanisms, and exemptions for currently unavoidable uses.

Policy Scope

Substance
Per- and Polyfluoroalkyl Substances (PFAS)
Applies to intentionally added PFAS in consumer products covered under the proposed model legislation.

Policy Framework
Model Legislative Act
Provides states with a template for PFAS product bans, reporting, testing, enforcement, and exemption provisions.

Unlike existing state PFAS laws, this proposal is not legally binding. Instead, it serves as a comprehensive legislative template that individual states may adopt or modify when developing future PFAS regulations.

Key Dates & Compliance Timeline

  • Official publication: June 1, 2026
  • Effective date: Not applicable — this is a model policy and has not been enacted into law
  • Compliance deadline: None unless adopted by an individual state
  • Proposed milestones: January 1, 2028 for manufacturer reporting and product prohibitions (only if enacted by a state legislature)

Key Policy Provisions

  • Phased prohibitions on intentionally added PFAS
  • Mandatory manufacturer reporting
  • Product testing upon state request
  • Recordkeeping requirements
  • Exemptions for currently unavoidable uses

Who Is Affected

  • Manufacturers and importers
  • Distributors and retailers
  • Automotive, electronics and textile industries
  • Cosmetics, cookware, cleaning product and packaging manufacturers
  • Compliance professionals and businesses marketing PFAS-containing consumer products

What Companies Should Do Now

  • Monitor whether individual U.S. states introduce legislation based on the model
  • Review product portfolios for intentionally added PFAS
  • Strengthen PFAS supply-chain disclosure and reporting capabilities
  • Prepare for possible expansion of state PFAS product restrictions modeled on this framework
Key Takeaway

This medium-priority development provides a blueprint for future state PFAS legislation rather than creating immediate legal obligations. Automotive OEMs, suppliers, manufacturers, and other businesses selling consumer products in the U.S. should monitor state legislative activity, assess PFAS content across product portfolios, and strengthen compliance documentation in anticipation of future state adoption.

Reference:
American Legislative Exchange Council (ALEC) – PFAS Model Policy Act

 

Reach out to our regulation experts on chemical and product regulatory compliances

CONTACT US