These quick updates were provided to PPAI’s Product Responsibility Action Group during its March meeting by Karolyn Helda, QIMA, and Rick Brenner, Product Safety Advisors:

European Union: Toy Safety Directive

The European Commission adopted Directive 2026/192 amending the Toy Safety Directive on cobalt.

  • Cobalt was reclassified in 2020 as a Category 1B CMR under Regulation (EC) No 1272/2008 on classification, labeling and packaging of substances and mixtures, as amended,and is generally prohibited in toys unless specifically permitted.
  • This amendment grants exemptions allowing cobalt in stainless steel (as impurity), certain electrical circuits and some magnets.
  • Surface coating cobalt limits remain unchanged.


California: Textile EPR

California has selected Landbell USA as the producer responsibility organization (PRO) for the state’s Responsible Textile Recovery Act (SB 707), the first statewide extended producer responsibility (EPR) program for textiles in the United States. Producers must register with the PRO by July 1.

CalRecycle is hosting a public meeting regarding SB 707 on April 7 from 10 a.m. to noon (Pacific):


United States: PFAS State Regulations

Maryland lawmakershave proposed a law (SB 686) to ban PFAS in cleaning products, cookware, cosmetics, personal care, feminine hygiene and juvenile products starting in 2028, with textiles and textile furnishings added Jan. 1, 2029.


Minnesota has launched the PFAS Reporting and Information System for Manufacturers (PRISM) under Amara’s Law.

  • Manufacturers must register, pay fees and report intentionally added PFAS in products/components by July 1, 2026.
  • This marks transitional reporting ahead of broader product bans and a default “PFAS‑free unless unavoidable” regime by 2032.


Missouri lawmakers have proposed a law (HB 2400) to prohibit intentionally added PFAS in specified product categories beginning Jan. 1, 2027.

  • Requires manufacturers to report intentionally added PFAS to the Department of Natural Resources.
  • Includes misdemeanor penalties for violations.
  • Envisions broad prohibition for all products by 2033 unless PFAS use is deemed unavoidable.


New York lawmakers have proposed a bill (S9073A) that would restrict PFAS in covered products (including textiles, cookware, architectural paint, cleaning products, etc.).

  • Applies to intentionally added PFAS and PFAS above a future total organic fluorine threshold (limit not yet defined).
  • Requires manufacturers to provide certificates of compliance to sellers.


A proposed amendment (HB 7621) to Rhode Island’s existing PFAS regulation (Consumer PFAS Ban Act of 2024) would add exemptions for certain food‑contact products where PFAS migration is negligible (e.g., fluoropolymers like polytetrafluoroethylene (PTFE).

  • This would align state law with the federal U.S. Food & Drug Administration’s view that nonstick, highly polymerized coating applications on pots and pans pose low risk of PFAS migrating into food.


Other Proposed U.S. State Regulations

Maryland lawmakers have proposed the Artificial Intelligence Toy Safety Act (HB 1261) to establish child safety and data privacy requirements for toys featuring artificial intelligence.

  • The bill would require an artificial intelligence toy to include certain labeling and prohibit the manufacturer of an artificial intelligence toy from using certain data for certain marketing.
  • This is an early signal that AI‑integrated consumer products (including toys) will face specific safety and compliance scrutiny.


Rhode Island lawmakers have proposed the Microplastics Reduction Act (SB 2534):

  • From Jan. 1, 2030, the law would prohibit products with intentionally added synthetic polymer microparticles (e.g., microbeads in personal care/cleaning products).
  • By July 1, 2029, the state would be required to develop a testing plan for environmental microplastics (including tire wear), with biennial updates and a broader strategy on health/environmental impacts by 2030.


Washington lawmakers have proposed amendments (SB 5975/HB 2344) to the state’s Cookware Containing Lead law (2024). Changes would include:

  • Maintains current 90 ppm lead limit in cookware surface coatings. The previously planned reduction to 10 ppm has been removed.
  • From Jan. 1, 2027, bans intentionally added lead for functional purposes in aluminum and brass cookware.
  • Lead limits for aluminum/brass pots and pans lowered to 50 ppm in 2030 and 20 ppm in 2034.
  • Exemptions where aluminum/brass are fully enclosed by stainless steel and for bodies of certain electrical cooking devices (e.g., rice cooker bodies).
  • Cookware containing lead designated a “priority consumer product.” The state would reconsider lead levels and adopt possible new rules by June 2033.


U.S. CPSC RECALLS

The federal Consumer Product Safety Commission has continued its aggressive approach this year. The document below lists the 48 product recalls from Feb. 9 through March 5. (View CPSC Recall Guidance here.) Key categories include button cell batteries and magnetic products (both ingestion risks).

CPSC Recalls 2026 – Weeks 7-10Download

Potential Leadership Changes At CPSC

  • Two Republicans have been nominated for CPSC commissioner posts: William Hewes III (withdrawn) and Karen Sessions.
  • Current acting chair Peter Feldman has not been nominated as permanent chair.


eFiling: Expect Delays

Express carriers (FedEx, et al) expect significant shipment delays starting in July when the CPSC’s new eFiling requirements take effect. Importers are encouraged to prepare and front‑load shipments where possible.


Recommended Reading

Rick Brenner recommended the Crowell & Moring Retail & Consumer Products Law Observer blog for timely updates on product safety legislation, regulatory agency policy changes and more.