Illinois PFAS Reduction Act

By the Opora Editorial Team

Illinois built its PFAS regulatory framework around a dual mechanism that distinguishes it from peer states: a mandatory manufacturer reporting pipeline feeding an Illinois EPA compliance database, and a phased product-ban schedule keyed to the ecological sensitivity of the Lake Michigan watershed. The foundation is the PFAS Reduction Act, originally enacted as Public Act 102-290 (SB 561, August 6, 2021) and codified at 415 ILCS 170. Successive amendments — most recently Public Act 104-0231 (HB 2516, August 15, 2025) — have layered consumer-product prohibitions onto that firefighting-foam core. For commercial cleaning operators supplying accounts from the Chicago lakefront to Downstate distribution hubs, the Act's expanding scope across cleaning products, carpets, and institutional textiles makes proactive inventory review an operational necessity.

The Reporting-Database Mechanism: How Illinois EPA Tracks PFAS Products

The statute's most operationally significant feature for supply-chain managers is its mandatory disclosure architecture. Under 415 ILCS 170/45(c), by August 1, 2027, the Illinois Environmental Protection Agency must submit a legislative report assessing the regulatory infrastructure, funding, and research capacity needed to administer a full fluoropolymer-review program. The enacted HB 2516 explicitly grants IEPA authority to develop reporting protocols, and pending bills such as HB 5042 (103rd General Assembly) demonstrated legislative intent to require manufacturers to submit product-level PFAS data to IEPA before any ban takes effect — creating a de facto registration database analogous to Minnesota's PRISM system. Commercial cleaning distributors should anticipate mandatory disclosure requirements emerging from IEPA rulemaking before 2027, well ahead of the 2032 consumer-product ban date.

When IEPA believes a product contains intentionally added PFAS, it may direct the manufacturer to provide, within 30 days, either laboratory testing results or a certificate attesting the product is PFAS-free. This certificate-and-testing mechanism shifts the burden of proof to the manufacturer and creates documentary trails that enforcement attorneys can subpoena. Distributors holding inventory from manufacturers who have not issued certificates of compliance face legal exposure once a ban takes effect.

Lake Michigan Watershed Rationale

Illinois draws 83 percent of its municipal water from Lake Michigan. The Illinois EPA PFAS Statewide Investigation Network sampled 18 PFAS analytes across community water supplies, each at a minimum reporting level of 2 nanograms per liter using U.S. EPA Method 537.1. Results informed the state's urgency around consumer-product elimination: PFAS present in carpets, textile furnishings, and floor-care products shed into wastewater and, through stormwater, into Lake Michigan tributaries. Governor Pritzker signed SB 727 in March 2025, directing the Illinois Pollution Control Board to establish maximum contaminant levels (MCLs) for community water supplies — the first binding MCL action in state history. For janitorial chemical formulators, this MCL framework creates a downstream liability pathway that reinforces the product-ban rationale.

Phase-by-Phase Ban Schedule Under 415 ILCS 170

Illinois's product-prohibition timeline spans a decade and affects commercial cleaning in several waves:

January 1, 2022 (in effect): Ban on using Class B firefighting foam containing PFAS for training or testing (415 ILCS 170/10(a)).
January 1, 2025 (in effect): Ban on manufacture and sale of Class B AFFF containing intentionally added PFAS (415 ILCS 170/10(b)); extended to 2027 for refineries and tank farms that filed timely notice.
January 1, 2026: Sellers of firefighting personal protective clothing containing PFAS must furnish written notice to purchasers; notice retained for at least 3 years (415 ILCS 170/20(a)).
January 1, 2027: Ban on sale and manufacture of firefighting personal protective clothing containing intentionally added PFAS (415 ILCS 170/20(b)).
January 1, 2028: Bans on carpets and rugs, cleaning products, cosmetics, fabric treatments, textiles, textile furnishings, ski wax, and upholstered furniture containing intentionally added PFAS. Commercial cleaning operators must audit all floor-care chemistry, encapsulation agents, and fabric protectants against this horizon.
January 1, 2032 (P.A. 104-0231): Ban on cosmetics, dental floss, juvenile products, menstrual products, and intimate apparel containing intentionally added PFAS (415 ILCS 170/45(a)); general prohibition on all products unless the Pollution Control Board has determined the use is "currently unavoidable."

What "Cleaning Product" Means Under Illinois Law

The statutory definition is broad and operationally consequential. A "cleaning product" means a finished product used primarily for domestic, commercial, or institutional cleaning purposes, including: an air care product, an automotive maintenance product, a general cleaning product, and a polish or floor maintenance product. That last category is critical: floor waxes, floor finishes, high-speed burnishing compounds, and stripping solutions all fall within scope. A janitorial distributor stocking PFAS-containing floor finish will be in violation of Illinois law when the 2028 prohibition takes effect, even if the product is marketed as "industrial." The "carpet or rug" definition covers any fabric marketed or intended for use as a floor covering, encompassing commercial broadloom, entrance matting, and modular carpet tiles. Fabric treatments — substances applied to fabric to provide stain resistance or water resistance — are also prohibited in the 2028 wave, directly affecting encapsulation and carpet-protection services.

Civil Penalties and Enforcement Authority

The penalty structure under 415 ILCS 170/35 is tiered by offense history:

First violation: Civil penalty not to exceed $5,000
Each subsequent violation: Civil penalty not to exceed $10,000

The same penalty caps apply to non-manufacturer persons (retailers, distributors) who knowingly violate consumer-product prohibition sections under 415 ILCS 170/45(d). Civil penalties flow to the Environmental Protection Trust Fund. Enforcement authority rests with the Illinois Environmental Protection Agency, the Illinois Attorney General, and the State's Attorney of the county where the violation occurs (415 ILCS 170/45(e)). Multi-location operators face per-location exposure: each sale of a prohibited product can constitute a separate violation. The IEPA may also coordinate with the Pollution Control Board, the Department of Agriculture, and the Department of Public Health.

Exemptions and Federal Preemption Carve-Outs

Under 415 ILCS 170/45(b), the consumer-product prohibitions do not apply to: (1) products for which federal law governs PFAS content in a manner that preempts state authority; (2) used products offered for sale or resale; (3) electronic or internal components of a product; (4) refrigerants, foams, and aerosol propellants; and (5) prosthetic or orthotic devices, medical devices, or drugs regulated by the FDA. Unlike Maine and Connecticut, Illinois includes a limited exemption for certain solid fluoropolymers if the IEPA approves them as posing no environmental or health threat — but this requires an affirmative IEPA determination, not a default pass.

Compliance Actions for Illinois Commercial Cleaning Operators

Audit floor-care chemistry now: Identify every floor wax, floor finish, and encapsulant that may contain PFAS-based leveling agents. Request certificates of compliance or SDS attestations from formulators by end of 2025.
Map carpet-care products to the 2028 ban: Fluorotelomer-based protectants and fiber treatments will be prohibited. Transition to fluorine-free alternatives — silicone-based or hydrocarbon chemistry — to avoid stranded inventory.
Establish 3-year document retention: Retain supplier attestations, certificates of compliance, and SDS documents for at minimum 3 years from each transaction date, mirroring the PPE-notification standard in 415 ILCS 170/20(a).
Monitor IEPA fluoropolymer rulemaking: Subscribe to the Illinois EPA PFAS updates page for post-2027 rulemaking notices affecting solid fluoropolymer exemptions.
Insert PFAS-free language in procurement specs: Require manufacturers of microfiber cloths, mop heads, scrubber pads, and entrance matting to provide written confirmation of PFAS-free status, retained per the 3-year standard.
Review uniform programs: PFAS-treated uniforms with stain-release or water-repellent finishes face prohibition under the textiles category in 2028. Coordinate with uniform service providers to transition to fluorine-free finishes.

Bid-Template Language and Primary Sources

"All cleaning products, floor-care products, fabric treatments, and textile goods supplied under this agreement shall contain no intentionally added per- or polyfluoroalkyl substances (PFAS) as defined under the Illinois PFAS Reduction Act, 415 ILCS 170, and any successor IEPA rulemaking. Supplier shall provide, within 30 days of any IEPA inquiry, a certificate of compliance or third-party laboratory test results demonstrating absence of intentionally added PFAS. Supplier shall retain documentation for a minimum of three (3) years from each transaction date."

Key references: statute text — ILGA.gov 415 ILCS 170; Illinois EPA PFAS — epa.illinois.gov/topics/water-quality/pfas; HB 2516 analysis — lawbc.com Illinois HB 2516; ECOS summary — ECOS Illinois PFAS Reduction Act; NCSL tracker — NCSL PFAS State Legislation.

Primary sources

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.

Use the PFAS state lookup tool →

Illinois PFAS Reduction Act — Cleaning Product Restrictions