These quick updates were provided to PPAI’s Product Responsibility Action Group during its November 2025 meeting by Karolyn Helda, QIMA:
Potential Change To Federal PFAS Reporting Rules
The U.S. Environmental Protection Agency has proposed amendments to the final rule from October 11, 2023, for PFAS reporting and recordkeeping under the Toxic Substances Control Act. The 2023 rule required each person who has manufactured a chemical substance that is a PFAS in any year since January 1, 2011 to report any amounts of PFAS which were known to or reasonably ascertainable by the manufacturer, including imported PFAS-containing articles.
The proposed amendments for PFAS reporting and recordkeeping include exemptions and modifications to reduce reporting on activities that manufacturers are least likely to know or reasonably determine. Extending this exemption to imported articles would be a significant reduction in the reporting burden companies face.
- See EPA Proposes Changes To PFAS Reporting Requirements for more details and a link to provide comments. The comment period closes December 29.
Bill Filed To Increase CPSC Focus On Products From China
A bill filed in the Senate in October – S.3069, the Protecting Americans From Harmful CCP Products Act – would amend the Consumer Product Safety Act to give the Consumer Product Safety Commission enhanced authority to deal with potentially hazardous products originating from China.
The bill has not gained traction, but it would allow the CPSC to issue mandatory recalls (without cooperation from the manufacturer/importer) for consumer products that present a substantial hazard if the manufacturer or retailer is located in the People’s Republic of China, including Special Administrative Regions Hong Kong and Macao.
Interestingly, the definition of a “distributor” in the CPSA would be modified to explicitly include e-commerce platforms headquartered in or primarily operating from China.
California Requests Information On Bisphenols
California’s Office of Environmental Health Hazard Assessment has requested information on the reproductive toxicity of certain bisphenol chemicals. The class of p,p’ bisphenol chemicals was selected for review and consideration for listing as reproductive toxins under California Proposition 65, which already lists bisphenol A and bisphenol S.
It’s highly likely the promotional products industry will be impacted, as these chemicals can be found in a wide range of products including various plastic parts, food packaging and textiles – particularly athletic poly/spandex blend fabrics. Importantly, the state makes no differentiation between general use and children’s products.
- Submit comments to OEHHA by December 1.
New Mexico Proposes PFAS Product Labels
In April 2025, New Mexico enacted its law prohibiting certain PFAS substances on specific product categories, starting January 1, 2027, with cookware, food packaging, children’s products and more.
The state has proposed an additional rule that would require manufacturers to use a specific consumer-facing label in English and Spanish for products with intentionally added PFAS, as well as a label for the packaging of those products.
After January 1, 2027, a manufacturer would not be allowed to sell, offer for sale, distribute or distribute for sale a product containing intentionally added PFAS without the required label(s).
- Read the proposed rules here.
- Provide comments on the proposed rule by March 31, 2026.
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