By the Opora Editorial Team
California has built the most layered state PFAS regulatory architecture in the United States, stacking four interlocking statutes — the Safer Clothes and Textiles Act (AB 1817), the Cosmetic Safety expansion (AB 2771), the PFAS Reporting and Registry Act (AB 2247), and DTSC's Safer Consumer Products (SCP) program — into a framework that reaches every textile, personal-care product, and floor covering sold in the state. For commercial cleaning operators, Silicon Valley cleanroom contractors, and institutional laundry programs, the combined effect is decisive: PFAS-treated uniforms, microfiber mop heads, carpet-care chemicals, and institutional hand soaps are now subject to multiple intersecting compliance obligations, each with its own timeline, threshold, and enforcement teeth.
AB 1817 — The Safer Clothes and Textiles Act
Signed by Governor Newsom on September 29, 2022, AB 1817 is codified at California Health and Safety Code §§ 108970–108971. It prohibits the manufacture, distribution, or sale of any new textile article containing "regulated PFAS" beginning January 1, 2025. The initial threshold is 100 parts per million (ppm) total organic fluorine (TOF), tightening to 50 ppm TOF on January 1, 2027. "Textile article" covers apparel, accessories, handbags, backpacks, draperies, shower curtains, furnishings, upholstery, bedding, towels, napkins, and tablecloths — nearly every fabric product used in a commercial cleaning environment.
Manufacturers must supply distributors and sellers with signed certificates of compliance. A distributor who relies in good faith on a valid certificate is shielded from liability. AB 1817 excludes carpets and rugs (governed separately by DTSC), industrial filter media, PPE, military-exclusive garments, and vehicles. Outdoor apparel for severe wet conditions receives a delayed ban until January 1, 2028 but must carry a "Made with PFAS chemicals" disclosure starting January 1, 2025. In September 2024, AB 347 added registration, testing, and enforcement mechanics: by July 1, 2029, manufacturers must register with DTSC and submit test results; starting July 1, 2030, DTSC may issue Notices of Violation with minimum penalties of $10,000 for the first violation, assessed daily for continuing violations.
AB 2771 — Cosmetics PFAS Ban
AB 2771, codified at Cal. Health & Safety Code § 108981.5, prohibits manufacturing, selling, or offering for sale any cosmetic product containing intentionally added PFAS beginning January 1, 2025. Unlike the 2020 predecessor targeting 13 specific compounds, AB 2771 covers the entire class — more than 12,000 substances. For commercial cleaning companies supplying hand sanitizers, moisturizing soaps, or institutional personal-care products to clients, this requires a full ingredient-level audit. The statute targets "intentionally added" PFAS rather than incidental trace contamination. Enforcement may proceed through California's Unfair Competition Law (private suits) and DTSC's SCP penalty authority of up to $50,000 per violation per day under Cal. Health & Safety Code § 25253.7.
AB 2247 — PFAS Reporting Registry
AB 2247 directed DTSC to collaborate with the Interstate Chemicals Clearinghouse (ICC) to build a publicly accessible PFAS reporting platform. Manufacturers of PFAS or of products containing intentionally added PFAS sold into California must register and disclose: product name, UPC, intended use, all PFAS CAS registry numbers, TOF measurements per analyte, annual quantity distributed into the state, and manufacturer contact information. The platform was due by January 1, 2025; manufacturer reporting commenced by July 1, 2025 and is annual thereafter. Commercial cleaning distributors whose brand name appears on any PFAS-containing product are treated as manufacturers for reporting purposes.
DTSC's Safer Consumer Products Priority Products Program
Separate from the statutes above, DTSC's SCP program designates specific product-chemical combinations as Priority Products, triggering mandatory alternatives analyses. As of July 2021, carpets and rugs containing PFAS became the fourth Priority Product. Responsible entities — manufacturers, importers, retailers — had to file Priority Product Notifications (PPNs) through DTSC's CalSAFER portal, followed by alternatives analyses. In March 2026, DTSC released a draft product-chemical profile evaluating floor maintenance products containing PFAS as a potential Priority Product — directly targeting floor finishes, sealers, and strippers. If finalized, manufacturers face notification, alternatives-analysis, and potential reformulation obligations. Non-compliance with SCP regulations may result in penalties up to $50,000 per violation per day under § 25253.7.
DTSC previously designated treatments containing PFAS for converted textiles or leathers as a Priority Product; manufacturers of carpet-treatment sprays, upholstery protectors, and stain guards were required to submit PPNs through CalSAFER with a May 31, 2022 deadline. Companies that have not notified CalEPA of reformulation or product-removal intent remain in potential violation. The DTSC program home page at dtsc.ca.gov/safer-consumer-products maintains the current Priority Products list and workplan updates.
Scope for Cleaning Operators
- Uniforms and workwear: Certificates of compliance required; thresholds are ≤100 ppm TOF (2025) and ≤50 ppm (2027).
- Microfiber mop heads and cleaning cloths: Textile articles under AB 1817; same certificate requirements apply.
- Carpet and floor-care chemicals: PFAS-containing carpet treatments are an existing Priority Product; floor-maintenance products are under active Priority Product evaluation.
- Hand soaps and personal care: Cosmetics under AB 2771 — no intentionally added PFAS as of January 1, 2025.
- Food-contact textiles: Aprons, napkins, and kitchen linens are textile articles under AB 1817; food packaging separately banned under Cal. Health & Safety Code § 109000 since January 1, 2023.
Enforcement Agency
The California Department of Toxic Substances Control (DTSC) is the primary enforcement agency for AB 1817, AB 347, and the SCP program. DTSC issues NOVs, conducts product testing, and imposes administrative penalties. The California Attorney General may independently pursue injunctive actions. DTSC's SCP team is reachable through the CalSAFER portal and the program page at dtsc.ca.gov/safer-consumer-products.
Compliance Steps
- Collect certificates of compliance from every uniform, mop, cloth, and linen supplier confirming TOF levels below 100 ppm (or 50 ppm after 2027).
- Audit cosmetic and personal-care product SKUs for intentionally added PFAS; obtain ingredient-level attestations.
- Register on the DTSC/ICC PFAS reporting platform by July 1, 2025 if your brand name appears on any PFAS-containing product in California commerce.
- Cross-reference all floor-care SKUs against DTSC's draft floor maintenance Priority Product profile and prepare for notification obligations if finalized.
- Confirm CalSAFER PPNs for any PFAS-containing aftermarket textile/leather treatment products sold in California.
- Update supplier contracts with PFAS-free warranty clauses incorporating AB 1817, AB 2771, and SCP references.
- Subscribe to DTSC's CalSAFER notice list for Priority Product workplan updates.
Bid Template Language
For California public-agency cleaning contracts, include: "All textile articles and apparel furnished under this contract shall comply with Cal. Health & Safety Code § 108970 (AB 1817) and contain no regulated PFAS at or above 100 ppm TOF (50 ppm after January 1, 2027). All cleaning products, hand soaps, and personal care items shall be free of intentionally added PFAS per Cal. Health & Safety Code § 108981.5 (AB 2771). Contractor shall supply DTSC-compliant certificates of compliance for all textile articles and maintain copies for a minimum of five years."
Key Statute Summary
| Statute | Code Section | Effective Date | Requirement |
|---|---|---|---|
| AB 1817 | §§ 108970–108971 | Jan. 1, 2025 / Jan. 1, 2027 / Jan. 1, 2028 | Textile ban at 100 ppm, 50 ppm, outdoor apparel |
| AB 2771 | § 108981.5 | Jan. 1, 2025 | No intentionally added PFAS in cosmetics |
| AB 2247 | DTSC/ICC platform | July 1, 2025 (reporting) | Annual PFAS product registry registration |
| SCP Regulations | 22 Cal. Code Regs. § 69501 et seq. | Ongoing | Priority Product Notifications; alternatives analyses; up to $50,000/day |
| AB 347 | §§ 108970–108971 (amended) | July 1, 2030 (enforcement) | DTSC testing; min. $10,000 first-violation NOV |
Primary sources
- AB 1817 — Safer Clothes and Textiles Act (Cal. Health & Safety Code §§ 108970–108971)
- AB 2771 — Cosmetic Products: Safety (Cal. Health & Safety Code § 108981.5)
- DTSC Safer Consumer Products Program — Priority Products
- DTSC Carpets and Rugs PFAS Priority Product Listing
- Morgan Lewis — California PFAS Textile Bans Begin January 2025
- Kelley Drye — California AB 347 Enforcement Criteria (Oct. 2024)
- Alston & Bird — DTSC Expands SCP Program, Floor Maintenance Products PFAS (Mar. 2026)
Related PFAS resources
- PFAS state lookup tool — interactive ban calendar across all 50 states.
- PFAS in cleaning products: the 2026 state-by-state ban calendar
- Green Seal, EcoLogo, Safer Choice & CIMS-GB pathways
- Buying smart hub — chemical sourcing and certification guides.
Other states with active PFAS legislation
Each linked state has codified restrictions on intentionally added PFAS in cleaning chemistry. Effective dates, scope, and disclosure rules vary; verify the operative statute for any compliance decision.