Perfluoroalkyl and polyfluoroalkyl substances (PFAS) have been used in floor finish and wax formulations for decades because they provide exceptional durability, leveling, and soil resistance. They also persist indefinitely in the environment and accumulate in human tissue. By 2024, Maine had enacted the broadest PFAS product restriction law in the country, Minnesota had passed a comprehensive PFAS in products law effective 2025, and California's AB 1817 restricted PFAS in several consumer and institutional product categories. The BSC industry is directly affected because floor care products, some hard surface cleaners, and carpet care treatments have historically relied on PFAS chemistry.
There is no single federal PFAS product restriction law equivalent to the state programs currently in effect. EPA has proposed PFAS regulations under the Toxic Substances Control Act and the Clean Water Act, and the EPA PFAS page tracks current federal regulatory actions. But for product compliance today, state laws govern, and the patchwork of effective dates and covered substance lists requires a product-by-product, state-by-state analysis for any BSC operating in multiple states.
State PFAS Laws Affecting Cleaning Products
The state programs vary in scope, covered product categories, and effective dates. The most significant for cleaning contractors are summarized below. This table reflects the laws as enacted or effective through early 2026; consult the current state statute for updates.
| State | Law/Reference | Covered Categories (Cleaning-Relevant) | Effective Date |
|---|---|---|---|
| Maine | LD 1503 (38 MRSA §1614) | Virtually all products containing intentionally added PFAS; disclosure requirements starting 2023; general prohibition starting 2030 | Disclosure: 2023; Prohibition: 2030 |
| Minnesota | HF 2310 (Minn. Stat. §116.943) | Cleaning products, waxes and polishes, and related products; prohibition on manufacture and sale of products with intentionally added PFAS | January 1, 2025 |
| California | AB 1817 (Health & Safety Code §108980) | Certain consumer products; industrial and institutional cleaners have separate rulemaking under DTSC authority | 2025 for most covered categories |
| Washington | ESHB 1694 | Cleaning products containing PFAS; restrictions on sale | January 1, 2023 for firefighting foam; product categories phased |
| Colorado | HB 21-1119 | Products containing intentionally added PFAS; reporting requirements | Phased 2024 through 2026 |
The Minnesota law at Minn. Stat. §116.943 is the most directly relevant to BSCs because it explicitly covers cleaning products and waxes effective January 1, 2025. A BSC operating in Minnesota that purchases or uses a floor finish containing intentionally added PFAS after that date is using a product that cannot legally be sold in Minnesota. The manufacturer bears the primary compliance burden, but a BSC who buys a non-compliant product from an out-of-state distributor is using a restricted substance in a restricted jurisdiction. The Minnesota Pollution Control Agency PFAS page tracks current compliance status and enforcement priorities.
What "Intentionally Added" Means
Most state PFAS laws restrict "intentionally added" PFAS, meaning substances deliberately incorporated into the product formulation for a functional purpose. They do not restrict trace PFAS contamination that arrives through raw materials or packaging. For floor care products, the PFAS compounds historically used as performance additives (PFOA, PFOS, their precursors, and longer-chain replacements) are intentionally added and covered by these restrictions. The short-chain PFAS compounds introduced as replacements after the phase-out of PFOA and PFOS are also covered by most state laws, which do not distinguish between long-chain and short-chain PFAS for prohibition purposes.
Who Is Affected
BSCs operating in Maine, Minnesota, California, Washington, Colorado, and several other states with enacted or pending PFAS restrictions must verify that their floor care product portfolio does not contain intentionally added PFAS. This affects primarily: floor finishes and waxes (the highest-risk category), some hard surface cleaners with durability additives, some carpet protector treatments, and some tile and grout sealers. Formulators have accelerated PFAS-free product development since 2020, and most major cleaning chemistry manufacturers now offer PFAS-free floor finish lines. Performance characteristics vary: PFAS-free finishes in early product generations had shorter wear cycles and less soil resistance than their PFAS-containing predecessors. Current-generation PFAS-free formulations have substantially closed this gap, though some product data sheets still show longer recoat intervals compared to prior PFAS-based products.
Checking Product Compliance
| Verification Step | What to Ask or Check | Documentation to Retain |
|---|---|---|
| Request PFAS disclosure | Ask manufacturer/distributor for written confirmation that the product contains no intentionally added PFAS; request supporting formulation data if needed for state compliance | Written confirmation letter; date and product lot covered |
| Review SDS Section 2 and 3 | Check for any fluorinated compounds in the ingredient list; PFAS may be listed by trade name, CAS number, or generic description | SDS on file; note review date |
| Cross-reference state lists | Some states maintain lists of products confirmed to contain PFAS; check state agency resources for your operating states | Screen date and applicable state list reference |
| PFAS-free certification | Some manufacturers have obtained third-party PFAS-free certification; verify certification is current and covers the product version in your inventory | Certification document copy |
Tradeoffs and Operator Reality
The PFAS transition in floor care chemistry is real but uneven. In a test at a high-traffic retail account (60,000 sq ft, a shopping center anchor tenant), a BSC found that switching from a PFAS-containing finish to the manufacturer's PFAS-free equivalent in the same product line required recoating every 8 weeks instead of every 12 weeks to maintain acceptable gloss levels. Over a year, that added one full strip-and-refinish cycle and approximately 40 hours of additional labor for the account. The correct response is to adjust the service frequency in the contract to reflect the PFAS-free product's maintenance requirements, not to absorb the additional labor as a cost of compliance. BSCs who make the PFAS-free switch without adjusting the maintenance schedule and contract pricing will find the account unprofitable within 18 months.
What to Put in the SOW and Training Matrix
For accounts in states with PFAS restrictions, the SOW should specify that all floor care products used at the account are PFAS-free as defined by the applicable state law, identify the products by name and product number, and confirm the manufacturer's PFAS-free certification. The floor care maintenance schedule should reflect the PFAS-free product's actual performance parameters, not the maintenance interval from the prior PFAS-containing product. Training for floor care technicians at PFAS-restricted accounts should cover the product specifications and the reasons for the compliance requirement, so that substitutions are not made without authorization.
Use the PFAS state lookup tool to check the current PFAS restriction status for each state where your operation purchases or uses floor care products. For VOC compliance requirements that may also affect floor finish product selection, see EPA Clean Air Act VOCs in Cleaning Products. For Safer Choice certified floor care products that are typically also PFAS-free, see EPA Safer Choice and DfE Procurement. Full compliance reference at Opora Compliance Library. The EPA PFAS Strategic Roadmap outlines the federal regulatory trajectory for PFAS restrictions under TSCA and the Clean Water Act. The EPA PFAS fact sheet covers the health effects basis for the state and federal restrictions. The Minnesota PCA PFAS page provides current compliance status for the Minnesota HF 2310 restrictions on cleaning products. For office and commercial cleaning programs where floor care PFAS compliance is most frequently required, see the office cleaning vertical hub.
By the Opora Editorial Team · Last updated: 2026