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2026 chemicals regulations in the US
Find the answers to some of the most pressing questions around regulatory changes in the US for chemicals and products, in this Q&A with an Enhesa expert.
Bobby DeMuro, Deputy Editor, North America, Chemical Watch News & Insight answers some important commonly asked questions around regulatory changes occurring for compliance this year in the US.
Q1: What does the chemical legislative and regulatory landscape look like in 2026 for the US?
I expect 2026 to be a state-driven year, with states acting because they perceive a federal regulatory “vacuum” under the Trump administration and want to fill it. The practical result is a diffuse set of rules that’s harder to navigate, because requirements will vary by state, and by product category. PFAS is still the center of gravity, but the action around it won’t just be bans – it’ll also be on implementing laws. So, things like reporting systems, labeling obligations, testing methodologies, and enforcement ramp-ups will begin to come into play, particularly in states like Maine, Minnesota, New Mexico, Washington, and California. And I think we’ll keep seeing more policy “stacking”: new deadlines layered onto earlier actions as agencies move from wrapping their minds around recently-enacted statutes to the hard work of drafting and finalizing rules to implement those laws.
Q2: How is the patchwork of state chemical laws going to impact businesses?
I think the biggest impact is operational as companies must manage multiple, overlapping US state regimes instead of one clear national (federal) baseline. That could mean more SKU-level decision-making, with the need to: reformulate, re-label, restrict or alter sales plans in certain states, or take the time to ensure that products are compliant state-by-state depending on local laws. It could also put more pressure on supply chain management, as companies may need to retain data to prove what’s in – or not in – a product, and why. The risk profile also changes: labeling schemes like what is currently being proposed for PFAS-containing products in New Mexico are broad and can feel commercially unworkable. On top of that, increased private citizen and NGO attention on chemicals policy in consumer products – particularly in high-profile sectors like cookware and cosmetics – increases the odds that product claims are likely to be tested in the real world. Thus, I think a practical takeaway for businesses is simple: invest in compliance infrastructure early, be it manufacturing process data, vendor attestations, supply chain management and relationships, product testing strategies, a clear labeling game plan, product stewardship to understand varying obligations in many jurisdictions, or all the above.
Q3: Which state PFAS bans are kicking in or expanding, and what products are in the crosshairs?
Lots of prohibitions, particularly around PFAS, kicked in, or broadened, on 1 January. In Maine, expanded prohibition categories now include PFAS bans in consumer areas like cleaning products, cookware, cosmetics, dental floss, juvenile products, menstrual products, ski wax, upholstered furniture, and certain textile articles. Colorado’s next PFAS restriction phase also hit on 1 January, and it adds a notable twist by prohibiting PFAS-containing artificial turf. Vermont saw bans go into effect on PFAS in cosmetics and personal care items, clothing, cookware, and food packaging. New Jersey’s PFAS-containing firefighting-foam ban began a week after those, on 8 January. I could go on, with many more looming in the next couple of years, but that’s kind of the thing: many states are moving on various product restrictions, and on varying timelines. And while PFAS is the big target in that space, other substances, like various chemicals in cosmetics and personal care products, are also under scrutiny. I use the term “whack-a-mole” a lot, but that’s what companies need to be ready for when it comes to restrictions on chemicals in consumer products. Employing a very good product steward and seeking out reliable regulatory intelligence are both critically important in what is an increasingly complicated landscape to navigate.
Q4: What are the most likely ‘hotspots’ that will create the toughest compliance burden in 2026?
I think reporting requirements and product labeling mandates are likely where the real day-to-day work will pile up this year, because they demand defensible data and public-facing decisions. Minnesota has given manufacturers a deadline to report the use of PFAS in products sold in that state by 1 July, for example, and they are the big player in the reporting space right now. Illinois already has PFAS reporting for firefighting gear and certain PPE, too. For product labeling, Connecticut required that certain PFAS-containing outdoor apparel needed to be labeled beginning back on 1 January, and that labeling requirement expands across 12 more categories, beginning on 1 July. And New Mexico is critically important to watch, as they are currently in the middle of a rulemaking process to craft guidelines that will implement that state’s law restricting PFAS in most consumer goods by 2032. Most imminently, if New Mexico’s rulemaking proceeds as it has thus far been going, their PFAS reporting requirements would kick off in July. New Mexico is also considering a broad labeling mandate for most new products sold in-state, starting in 2027.
Q5: Are there any technical issues that could spark disputes in 2026?
I think testing methodology is going to be a recurring friction point, particularly the ongoing debate between using total organic fluorine (TOF) or total fluorine (TF) screening approaches to test for fluorine in a product and, thus, the potential presence of PFAS. For example, I’ve spoken to some experts who are concerned TF testing is too restrictive and could flag false positives indicating PFAS is present in a product when it might not be. Setting aside a debate about whether TOF or TF is the “preferred” testing method for various stakeholders, the broader issue suggests to me that headaches loom all around – for regulators handing down enforcement decisions based on whichever testing methodology is mandated by law or implemented by rule, and for companies trying to validate materials and ingredients in their products. I think another flashpoint could form around confidential business information (CBI) as companies continue to worry about protecting supplier relationships and proprietary formulations while still meeting regulatory obligations, and regulators pursue the tricky task of trying to thread the needle of maintaining a firewall around intellectual property while still getting the information they need to do their jobs.
Q6: How aggressive could enforcement get?
I’ve talked to multiple experts who expect more “outside-in” enforcement pressure. That is, I think 2026 might be a year where we see more environmental non-profits and highly motivated private citizens doing their own product screening, flagging suspected violations, and proactively sending that information to regulators. These state regulatory agencies are tasked with implementing and enforcing significant and sometimes complicated laws, and some must do so with very small staff. However, they are nimble, and very capable. And even more than that, private citizens and environmental NGOs are becoming better educated on the issues and more highly motivated as time goes on. People care greatly about what is in their products. Private citizens will scan online listings and scrutinize ingredient labels on the shelves, and they will not hesitate to flag suspected violators and alert regulators. Add social media on top of that, and I think companies would be wise to understand that public opinion can move very swiftly. Whether or not a certain chemical in a certain product is “dangerous” or “toxic” may be a moot point if public perception goes in that direction.
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Want more analysis on US regulations?
What’s next for state-level chemicals policy in the US in 2026?
Join the Chemical Watch News & Insight community to read this Global Outlook analysis by North America deputy editor, Bobby DeMuro. Bobby shares critical insights into the evolving story of US chemical regulation, explaining complex details of state level legal developments relevant to PFAS compliance.
