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Connecticut’s Department of Energy & Environmental Protection (DEEP) has said it will not issue extensions to comply with the state’s PFAS in Consumer Products Law.
DEEP’s statement came as part of an informational document released on 10 September. The document, which also included guidance about labelling requirements and exemptions, concluded with an advisory that companies with non-compliant products should begin labelling those items "immediately".
The warning indicates that manufacturers and retailers should not expect Connecticut to adjust its PFAS notification and labelling deadlines as some other states have, but also that DEEP may be flexible with companies that struggle to meet those deadlines.
‘It is taking time’
Connecticut’s 2024 PFAS law required companies and retailers to notify DEEP and begin labelling certain categories of products that contain PFAS by 1 July.
But Martha Marrapese at Wiley Rein said: "Compliance is often more complex than it appears on paper. The compliance timelines in many state PFAS programmes can be challenging to implement across complex supply chains."
While communication procedures among companies are now shifting to allow for the kind of reporting Connecticut requires, "it is taking time", Marrapese said.
DEEP itself released its informational document more than two months after the labelling and notification requirements took effect.
Connecticut’s approach
Connecticut’s commitment to its PFAS labelling and notification deadlines differs from state action taken elsewhere.
Minnesota extended its PFAS reporting deadlines twice before signalling it would not provide a third extension. The state also dropped certain product components altogether from its PFAS ban until 2032.
While Connecticut will not extend its original deadlines, it is "likely to be flexible for a while" in other ways, said Marrapese.
She pointed out, for example, that DEEP has accommodated manufacturers by accepting a range of label requests.
Even so, Marrapese said the overall message from DEEP is clear: "This is a law that was enacted in 2024. It is 2026, and the time for compliance has arrived."