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

EPA PFAS Reporting Requirement Under TSCA Delayed Again

  • Originally scheduled for November 2024, now starts January 31, 2027 (or 60 days after final rule).
  • Still applies to entities manufacturing/importing PFAS since 2011.
  • Delay allows EPA time to review public comments.
  • Proposed exemptions for imported articles likely to hold based on legal analysis.
  • Small Business Administration supports exemptions due to burden.

RELATED: Federal PFAS Reporting Period Postponed Again

New Mexico SB 212 (PFAS Protection Act) Implementing Rule Approved

  • Labeling for intentionally added PFAS required starting January 2027.
  • Applies only to products manufactured on/after January 1, 2027.
  • Labeling exemption requests due by October 31.
  • Exemptions available if labeling “not practicable.”
  • Phased in PFAS bans by product category begin January 1, 2027, culminating in an all-out ban of products with intentionally added PFAS by January 1, 2032, unless designated as a “currently unavoidable use”.

Minnesota “Amara’s Law” PFAS Reporting Deadline Pushed To September 15

  • Reporting for intentionally added PFAS required for products on the shelf on or after September 15 (originally July 1).
  • Extension/waiver requests due August 16; if granted, reporting then due by December 14.
  • PRISM 2.0 reporting platform released with improved user interface; database includes expanded chemical library, flexible menus, historical data replication.
  • Additional proposed legislation HF4257/SF5092 would delay initial reporting by one year (July 1, 2027), narrow scope to products manufactured on or after the reporting date, and add certain currently unavoidable uses as exemptions until the 2032 prohibition.

California Prop 65 Update

Michigan House Bill 5892 (Safe Cosmetics Act) Introduced

  • Restricts chemicals including PFAS, phthalates, parabens, formaldehyde, heavy metals; civil penalties start at $5,000.
  • Lead limits: 2 ppm for general cosmetics, 5 ppm for color cosmetics.
  • Excludes food/drugs except cosmetic drugs (e.g., moisturizer with sunscreen).
  • Compliance statements would be required within 10 days of request.
  • If adopted, enforcement would begin January 1, 2027

Maryland HB 1533 (Crown & Care Act) Approved

  • Compliance deadline July 1.
  • Extends existing Chapter 490 toxic chemical bans for cosmetics.
  • Adds lead restrictions and expands PFAS to full class (previously 13 specific chemicals).
  • Targets hair straightening/relaxer products with significant fines (funds to support restitution for affected consumers).

European Regulatory Developments

Proposed REACH amendment for childcare products:

  • Would restrict carcinogenic, mutagenic, reproductive toxins to 10 mg/kg.
  • Covers sleep, relaxation, hygiene, bathing products for children.
  • Aligns with existing toy safety directive restrictions.

Recycled plastic food contact materials proposal (Amendment to EU Regulation 2022/1616):

  • Strengthens traceability for recycled PET.
  • Electronic declaration of compliance required.
  • Focuses on preventing contamination from industrial plastics.
  • Establishes tracking codes throughout recycling process.

CPSC: Recent Major Product Recalls & More

The U.S. Consumer Product Safety Commission is continuing its accelerated pace of recalls. Recent products targeted include light-up toys, bicycle helmets, button battery pouches, water bottles, children’s hoodies with prohibited drawstrings, and Thermos bottles and food jars.

RELATED: 8 Million Thermos Food Jars, Bottles Recalled For Injury Risk

New CPSC e-filing requirements that take effect July 8 have sparked an uptick in questions to PPAI and supplier companies about tracking labels required under the Consumer Product Safety Improvement Act of 2008 (aka CPSIA), especially for children’s products.

LEARN MORE: Attend the PPAI Responsibility Summit, September 14-16 in Denver.