Navigating the Patchwork of US State PFAS Laws Affecting Food Packaging
While the US federal government has taken steps to phase out PFAS in food contact materials — notably the FDA's 2024 announcement that authorized PFAS uses had been voluntarily phased out by manufacturers — the real regulatory driver for food packaging businesses in 2026 is the rapidly expanding patchwork of state-level laws. With over 15 states enacting PFAS restrictions and more in the pipeline, understanding the timeline and requirements of each jurisdiction is essential for compliance.
This guide provides packaging professionals, procurement managers, and food brands with a state-by-state breakdown of PFAS regulations affecting food packaging, key deadlines, and a practical compliance roadmap.
Why State-Level PFAS Regulations Matter for Food Packaging
PFAS (per- and polyfluoroalkyl substances) have been widely used in food packaging for their oil- and water-repellent properties — in fast-food wrappers, pizza boxes, bakery bags, paper cups, and takeaway containers. As scientific evidence linking PFAS to health concerns has mounted, states have taken regulatory action where federal action has been slower.
For businesses selling food packaging or using it for their products, the result is a complex compliance landscape: a product that is legal in one state may violate another's laws, and deadlines vary significantly from state to state.
State-by-State PFAS Food Packaging Regulations
1. Minnesota — Ban in Effect (Since January 2025)
Law: Amara's Law (HF 3500)
Status: Most aggressive timeline to date. Minnesota banned the intentional addition of PFAS in 11 product categories — including food packaging — effective January 1, 2025.
Key requirements:
- Food packaging with intentionally added PFAS is prohibited from sale in Minnesota
- Manufacturers must report PFAS usage to the Minnesota Pollution Control Agency (MPCA) by July 1, 2026
- A broader ban covering all products with intentionally added PFAS takes effect January 1, 2032
2. California — Cookware and Disclosure (AB 1200)
Law: AB 1200 (Signed 2021)
Status: Effective January 1, 2024. Requires cookware with intentionally added PFAS to display a label stating "Contains PFAS" on the product and online sales platforms.
Key relevance for food packaging: While AB 1200 targets cookware specifically, California's broader PFAS regulatory trajectory signals tightening requirements for all food contact materials. The textile ban threshold drops from 100 ppm to 50 ppm on January 1, 2027.
3. Maine — Broad Product Ban (Effective January 2026)
Law: LD 1433 (Signed 2021)
Status: Effective January 1, 2026. Prohibits sale of products with intentionally added PFAS across multiple categories including food packaging and cookware.
Key requirements:
- Manufacturers must report PFAS content to the Maine Department of Environmental Protection
- Safer alternatives assessment required before exemptions can be granted
- One of the broadest state PFAS bans in effect
4. Washington — Reporting and Phase-Out
Law: Safer Products for Washington (SB 5178)
Status: Reporting requirements began January 1, 2026. Restrictions on PFAS in food packaging, cookware, and kitchen supplies take effect January 1, 2027.
Key requirements:
- Manufacturers must report PFAS presence in covered product categories
- Food packaging is a priority product category identified by the Washington Department of Ecology
- Phase-out enforcement begins 2027
5. Connecticut — Labeling Now, Ban Later
Law: Public Act 23-191
Status: Two-phase approach. Labeling requirements for products containing PFAS began July 1, 2026. Full sales ban on covered products (including food packaging and cookware) takes effect January 1, 2028.
Key requirements:
- Products with intentionally added PFAS must carry a label on packaging and online listings
- Full prohibition on sale begins 2028
6. New Mexico — First Mandatory PFAS Warning Label
Law: PFAS Protection Act (HB 212, Signed April 2025)
Status: Food packaging ban takes effect January 1, 2027. Introduces the first mandatory universal PFAS warning label — an Erlenmeyer flask symbol with "PFAS" — required on all products containing intentionally added PFAS.
Key requirements:
- Food packaging with intentionally added PFAS prohibited after January 1, 2027
- Universal PFAS warning label required from January 1, 2027
- Broader ban on most remaining products takes effect January 1, 2032
- Penalties up to $15,000 per day for noncompliance
7. New Jersey — Latest to Join (Effective 2028)
Law: Protecting Against Forever Chemicals Act (S 1042, Signed January 12, 2026)
Status: The most recently signed state PFAS law. Food packaging ban takes effect January 12, 2028 — two years after enactment.
Key requirements:
- Plant-fiber-based food packaging with intentionally added PFAS prohibited after January 12, 2028
- Cookware containing PFAS must carry bilingual label: "This product contains PFAS" in English and Spanish
- Source reduction program due by January 12, 2027
- Penalties up to $20,000 per violation
8. Vermont, New York, Colorado, Rhode Island
Vermont: Effective January 1, 2026, banned PFAS in textile articles. Broader food packaging legislation under consideration.
New York: Carpet PFAS ban effective December 31, 2026. Broader bill (S.9073A) addressing food packaging is pending.
Colorado: Indoor textiles and upholstery ban effective January 1, 2025. Cookware provisions under separate legislation.
Rhode Island: Enacted PFAS restrictions covering food packaging with requirements taking effect in 2027.
Federal Context
While state laws lead the charge, federal activity continues:
- FDA: Authorized PFAS uses in food contact applications voluntarily phased out by manufacturers as of 2024. No new PFAS-based food contact substances authorized.
- EPA: PFOA and PFOS designated as hazardous substances under CERCLA. TSCA PFAS Reporting Rule (one-time window: April 13 — October 13, 2026) applies to any manufacturer who has manufactured PFAS since 2011.
- Federal unified standard: Industry groups continue to advocate for a federal preemptive standard to replace the state patchwork, but no federal food packaging PFAS ban has passed Congress as of mid-2026.
Compliance Roadmap
Immediate Actions (July — December 2026)
- Audit your packaging: Identify all food contact materials and request PFAS-free certifications from suppliers
- Minnesota: Ensure products comply with the 2025 ban; prepare MPCA reporting (due July 1, 2026)
- Connecticut: Verify labeling compliance (effective July 1, 2026)
- Washington: Submit PFAS usage reports to Department of Ecology
- Test alternatives: Evaluate PFAS-free barrier papers like water-based coated barrier paper and PHA coated paper on your production lines
2027 Preparations
- New Mexico: Ensure PFAS-free compliance and labeling by January 1, 2027
- Washington: Full compliance with food packaging PFAS restriction by January 1, 2027
- Begin transition planning for Connecticut (2028) and New Jersey (2028) deadlines
- Consider PLA-coated paper for cold-serve applications and biodegradable barrier paper for general food wrapping
2028 and Beyond
- Connecticut: Full ban on PFAS in food packaging by January 1, 2028
- New Jersey: Full ban on PFAS in fiber-based food packaging by January 12, 2028
- Transition all product lines to PFAS-free alternatives
- Prepare for broader phase-outs (Minnesota and New Mexico 2032 deadlines)
PFAS-Free Barrier Solutions from Bofeng New Materials
Bofeng New Materials offers a comprehensive portfolio of PFAS-free barrier papers tested for food contact compliance and suitable for the US market:
- Water-Based Barrier Coating Paper: Excellent grease and water resistance, recyclable and repulpable — ideal for fast-food wrappers, cupstock, and food service board.
- PHA Coated Cupstock Paper: Home-compostable and marine-degradable with heat-seal capability — perfect for ice cream cups, lunchboxes, and takeaway containers.
- PLA Coated Barrier Paper: Industrially compostable with mature supply chain — suitable for cold beverage cups and food containers.
- Biodegradable barrier paper solutions: Including water-based coated, PHA coated, and PLA coated papers — tested for FDA food contact compliance and applicable state-level PFAS restrictions.
Conclusion
The US state-level PFAS regulatory landscape is complex and accelerating. With Minnesota's ban already in effect, Connecticut and New Mexico's 2027 deadlines approaching, and New Jersey's new law on the horizon, proactive compliance is essential. Food packaging businesses that audit their supply chain, test PFAS-free alternatives, and implement transitions now will avoid last-minute disruptions and capture growing market demand for sustainable packaging.
At Bofeng New Materials, we help packaging manufacturers and food brands navigate this transition with a full portfolio of PFAS-free barrier papers. Contact our technical team to discuss your specific requirements and state compliance needs.
This guide was published in June 2026 and reflects the regulatory landscape as of that date. State laws are subject to amendment; consult legal counsel for specific compliance advice.