Act 54 (H.238) expands the definition of 'intentionally added PFAS' effective July 1, 2027 to include: (1) PFAS added to provide a specific characteristic, appearance, quality, or function; (2) degradation byproducts of PFAS; (3) intentional breakdown products of added chemicals; and (4) PFAS used as processing agents, mold release agents, or intermediates where PFAS are detected in the final covered product. This expanded definition significantly broadens the scope of what constitutes a regulated PFAS addition in consumer products.
Vermont enacted Act 54 (H.238) amending 9 VSA Chapter 63 to establish comprehensive PFAS product phaseout with staggered effective dates. Products banned with intentionally added PFAS include: cosmetics and menstrual products (January 1, 2026); consumer products, food packaging, artificial turf, ski wax, textiles, juvenile products, incontinency products, rugs/carpets (January 1, 2026); cleaning products, dental floss, fluorine treated containers (July 1, 2027); cookware (July 1, 2028); personal protective equipment except respirators (July 1, 2029); and respirators (July 1, 2032). Station wear containing PFAS requires written notice beginning July 1, 2025. Manufacturers and distributors must assess product portfolios for PFAS content and plan compliance with phased prohibitions.
Act 54 (H.238) reduces the PFAS threshold for textiles and textile articles from 100 ppm to 50 ppm as measured in total organic fluorine, effective July 1, 2027. This tighter threshold significantly impacts compliance requirements for apparel and textile manufacturers selling products in Vermont. Products exceeding the 50 ppm threshold will be considered to contain intentionally added PFAS and subject to the sales prohibition.
Act 54 (H.238), signed into law on June 11, 2025, establishes phased PFAS prohibitions for firefighting equipment. Personal protective equipment (PPE) containing intentionally added PFAS is prohibited effective July 1, 2029. Respirators containing PFAS are prohibited effective July 1, 2032, with written notice requirements until that date. The law also requires written notice for station wear containing PFAS effective July 1, 2025. This complements the existing Class B firefighting foam restrictions.
Act 54 (H.238) adds dental floss and cleaning products to Vermont's PFAS product ban framework. Effective July 1, 2027, manufacturers are prohibited from manufacturing, selling, offering for sale, distributing for sale, or distributing for use in Vermont dental floss or cleaning products to which PFAS have been intentionally added. These product categories were added to the existing framework established by Act 131 (2024). Compliance teams should review product formulations for these categories and prepare for the 2027 prohibition.
Vermont Act 54 extends the effective date for the prohibition on sale and distribution of cookware containing intentionally added PFAS from January 1, 2026 to July 1, 2028. The original prohibition was established under Act 131 (2024). Manufacturers, importers, and distributors must update their compliance timelines accordingly for cookware products sold in Vermont.
Vermont Act 54 (2025) revises the PFAS product ban framework established in Act 131 (2024). The act restructures the statute for regulation of PFAS in consumer products, extends the cookware PFAS sales prohibition effective date to July 1, 2028, and establishes a prohibition on fluorine treated containers effective January 1, 2032. Products including cosmetics, menstrual products, certain consumer products, food packaging, and firefighting equipment are subject to PFAS restrictions effective January 1, 2026. The Secretary of Natural Resources must submit a report to the General Assembly by January 15, 2027.
The Vermont Attorney General's Office published comprehensive guidance on PFAS product bans under Acts 131 and 54. The guidance clarifies that covered products include cosmetics, menstrual products, consumer products, food packaging, Class B firefighting foam, and personal protective equipment with varying effective dates. For cosmetics and menstrual products, the guidance also details additional chemical restrictions beyond PFAS including ortho-phthalates, formaldehyde, mercury, lead, asbestos, and triclosan. The guidance provides practical compliance information for manufacturers and distributors.
The Vermont Attorney General's Office published guidance on PFAS product bans implementing Acts 131 (2024) and 54 (2025). The guidance explains covered products including cosmetics, menstrual products, certain consumer products, food packaging, Class B firefighting foam, and personal protective equipment, with varying effective dates beginning January 1, 2026. The guidance provides the public with a general understanding of the basic contours of the law.
Vermont Act 54 establishes a new prohibition on the manufacture, sale, or distribution of fluorine treated containers and consumer products in fluorine treated containers containing intentionally added PFAS, effective January 1, 2032. This adds a new product category to Vermont's PFAS product restriction framework. Companies in the packaging and consumer products supply chains must prepare for the 2032 compliance deadline.
The Vermont Agency of Natural Resources published the Act 131 (S.25) PFAS in Consumer Products Report, developed by the Act 131 PFAS Working Group. The report provides recommendations for implementing and revising PFAS phase-outs in consumer products in Vermont. This report formed the basis for Act 54 (H.238) legislation. Compliance teams should reference this document for understanding the policy rationale and implementation approach for Vermont's PFAS product restrictions.
Vermont prohibits intentionally added PFAS in cosmetics and menstrual products effective January 1, 2026 under 9 V.S.A. Chapter 63, Subchapter 12. PFAS is one of 14 chemicals banned in these product categories. The prohibition applies to manufacture, sale, offer for sale, distribution for sale, and distribution for use in Vermont. Manufacturers must ensure compliance by the effective date.