Connecticut PFAS Restrictions on Cleaning Products — SB 292

By the Opora Editorial Team

Connecticut's PFAS regulatory story began with food packaging and firefighting foam and has since grown into one of the most comprehensive product-banning regimes on the East Coast. The state's primary PFAS consumer product law, Senate Bill 292 / Public Act No. 24-59 (2024), codified at Connecticut General Statutes § 22a-903c, establishes a phased system of labeling, notification, and prohibition covering fourteen categories of consumer products. It builds upon the earlier Public Act 21-191, which banned PFAS in firefighting foam effective October 1, 2021, and in food packaging by December 31, 2023. For commercial cleaning operators holding federal Service Contract Act (SCA) agreements at Connecticut military bases, VA facilities, or GSA-managed buildings — Hartford, New Haven, Groton, and Bridgeport are all major federal footprint cities — the interaction of state law and federal GSA custodial specifications already requiring EPA Safer Choice cleaning products creates a de facto dual PFAS-free compliance obligation across virtually the entire cleaning portfolio.

The Food Packaging Foundation: Public Act 21-191

Public Act 21-191 (signed July 13, 2021) established two foundational PFAS prohibitions. First, it banned PFAS-containing Class B firefighting foam (AFFF) for training, testing, or non-emergency use effective October 1, 2021, with a mandatory CT DEEP take-back program for municipally owned AFFF, funded by a $2 million State Bond Commission allocation. Second, it prohibited the sale or use of any food packaging to which PFAS had been intentionally introduced during manufacturing, effective December 31, 2023. Connecticut was among the earliest states to operationalize a food packaging PFAS ban. For cleaning companies servicing food-manufacturing, food-distribution, or food-service accounts in Connecticut, any PFAS-treated paper packaging for food wrapping, deli service, or pizza delivery has been prohibited for over two years.

SB 292 / Public Act 24-59: The Three-Phase Framework

Governor Lamont signed SB 292 on June 5, 2024, effective October 1, 2024. The statute establishes a three-phase progression:

• Phase 1 — Disclosure (January 1, 2026): Outdoor apparel for severe wet conditions containing PFAS may be sold only if it carries a legible "Made with PFAS chemicals" disclosure, including online listings. Turnout gear with intentionally added PFAS requires written notice to the purchaser at time of sale stating that the gear contains PFAS and why.
• Phase 2 — Notification and Labeling (July 1, 2026): Manufacturers of twelve product categories containing intentionally added PFAS — apparel, carpets or rugs, cleaning products, cookware, cosmetics, dental floss, fabric treatments, children's products, menstruation products, textile furnishings, ski wax, and upholstered furniture — must: (a) submit prior written notification to CT DEEP with an $800 registration fee per product category, including all CAS registry numbers, PFAS percent-weight range, function of PFAS, and manufacturer contact; and (b) label all covered products with approved phrases such as "Contains PFAS," "Made with PFAS," or "Made with PFAS chemicals." Products cannot be sold in Connecticut without both steps completed.
• Phase 3 — Full Prohibition (January 1, 2028): No person may manufacture, sell, offer for sale, or distribute any of the fourteen covered product types containing intentionally added PFAS: apparel; turnout gear; carpets or rugs; cleaning products; cookware; cosmetic products; dental floss; fabric treatments; children's products; menstruation products; textile furnishings; ski wax; upholstered furniture; and outdoor apparel for severe wet conditions.

Cleaning Products and the Janitorial Portfolio

§ 22a-903c defines "cleaning product" to include any finished product used for domestic, commercial, or institutional cleaning: air care products, automotive maintenance products, general cleaning products, and polish or floor maintenance products. This definition encompasses the full janitorial product portfolio — floor finishes, sealers, strippers, degreasers, disinfectant cleaners, neutral cleaners, carpet spotters, and restroom cleaners. Unlike Colorado's exemption for hospital floor maintenance products through 2028, Connecticut treats all cleaning products identically: the full ban takes effect January 1, 2028, with notification and labeling required from July 1, 2026 for any PFAS-containing cleaning product that continues to be sold in the interim.

"Fabric treatments" — substances applied to fabric for stain or water resistance — directly affect PFAS-based carpet protectants, upholstery guards, and stain-resistant textile sprays. These products fall within the July 1, 2026 notification-and-labeling window and are banned entirely by January 1, 2028.

The Federal Custodial Contract Intersection

Connecticut hosts major federal custodial contracting footprints: Naval Submarine Base New London at Groton, Bradley Airport federal tenants, and numerous GSA-managed buildings across Hartford County. In April 2024, EPA and GSA directed government contractors performing custodial services at federal buildings to use EPA Safer Choice, Green Seal GS-37, GS-41, and GS-53 certified cleaning products, which prohibit intentionally added PFAS. This directive applies to all new contracts immediately and to existing contracts as they renew over five years. For Connecticut-based cleaning operators holding both state institutional contracts and federal SCA contracts, the compliance landscape is converging: state law will prohibit PFAS cleaning products by January 1, 2028, while federal specifications already require PFAS-free products on new contracts. Operators who transition early to Safer Choice or Green Seal-certified lines position themselves competitively in both markets.

Enforcement, DEEP, and Penalties

CT DEEP is the primary enforcement agency under the Commissioner's authority at Conn. Gen. Stat. § 22a-6. The Commissioner may hold hearings, issue orders, subpoena witnesses, enter injunctions, and institute legal proceedings. Upon written request, DEEP may require a certificate of compliance signed by an authorized manufacturer official, kept on file and made available through a multijurisdictional clearinghouse. General environmental violations under Connecticut law may attract civil penalties of up to $25,000 per day per violation under DEEP's Administrative Civil Penalty Regulations. DEEP coordinates enforcement with the Commissioners of Agriculture, Consumer Protection, and Public Health. The statute also bans the use of any biosolids or wastewater sludge containing PFAS as a soil amendment — relevant to waste-stream management at institutional or municipal facilities. Contact CT DEEP PFAS program at DEEP.PFASInProduct@ct.gov.

Exemptions Under § 22a-903c

Seven categories are exempt: (1) products where federal law requires PFAS preempting state authority; (2) products regulated separately under §§ 22a-903a or 22a-255i; (3) used-product resales; (4) FDA-regulated medical devices, drugs, prosthetics, or orthotics; (5) products made with at least 85% recycled content; (6) products manufactured before any applicable prohibition; and (7) replacement parts for pre-prohibition products. The 85% recycled-content exemption is noteworthy for the carpet and textile markets where post-consumer recycled-fiber products are increasingly common.

Compliance Steps

1. Audit your Connecticut product portfolio by June 2026 — identify every cleaning product, fabric treatment, textile furnishing, and cosmetic with potential intentionally added PFAS.
2. Register with CT DEEP by July 1, 2026 for any covered product that contains intentionally added PFAS and will continue to be sold. Submit the Reporting Form with the $800 fee to DEEP.CentralPermits@ct.gov, copying DEEP.PFASInProduct@ct.gov.
3. Apply DEEP-approved labels to covered PFAS-containing products sold after July 1, 2026: "Contains PFAS," "Made with PFAS chemicals," or equivalent approved language. Labels must be visible prior to sale and durable for the product's useful life.
4. Establish a certificate-of-compliance program — have authorized officials sign certificates for all covered products; maintain them on file and make them available through a multijurisdictional clearinghouse if requested.
5. Transition PFAS-containing lines to PFAS-free alternatives well ahead of January 1, 2028. For federal GSA contracts, Safer Choice or Green Seal GS-37 certification is already required on new contracts.
6. For food-packaging clients: confirm compliance with Public Act 21-191's December 31, 2023 food packaging ban and maintain supplier certifications on file.
7. Monitor DEEP rulemaking for regulations implementing fees and procedures under § 22a-903c(i) and for updates to approved labeling phrases.

Bid Template Language

For Connecticut state agency and municipal cleaning contracts, include: "All cleaning products, chemical supplies, fabric treatments, and textile articles furnished under this contract shall comply with Conn. Gen. Stat. § 22a-903c (Public Act No. 24-59). No covered product containing intentionally added PFAS may be supplied after January 1, 2028. Between July 1, 2026 and January 1, 2028, any PFAS-containing covered product must be pre-notified to CT DEEP and labeled with DEEP-approved PFAS disclosure language. Contractor shall provide certificates of compliance upon written request. For federal facility components, all cleaning products shall additionally be certified to EPA Safer Choice, Green Seal GS-37, GS-41, or GS-53 per GSA custodial specifications."

Key Milestone Table

Primary sources

• Connecticut SB 292 / Public Act No. 24-59 — Full Statute Text
• CT DEEP — PFAS in Products (Conn. Gen. Stat. § 22a-903c)
• Connecticut Public Act 21-191 — Firefighting Foam and Food Packaging
• Bergeson & Campbell — Connecticut PFAS Labeling Requirements (Dec. 2025)
• GSA — Biden-Harris Administration Directs PFAS-Free Federal Custodial Contracts (Apr. 2024)
• Fox Rothschild — Connecticut PFAS Labeling Requirements Effective July 1, 2026
• ISPA — Connecticut Governor Signs SB 292 (June 2024)

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.