By the Opora Editorial Team
Maryland's PFAS regulatory program centers on an industry foundational to commercial cleaning: the carpet and floor-covering sector. When Governor Larry Hogan signed HB 275 / SB 273 — the George "Walter" Taylor Act, Chapter 138, Acts of 2022 — on April 21, 2022, he put into law a prohibition aimed directly at carpets, rugs, and the padding installed beneath them. Named for firefighter George "Walter" Taylor, who died of cancer attributed to PFAS exposure from his protective equipment, the statute carries an emotional weight that extends beyond regulatory compliance. For rotary-extraction operators, encapsulation technicians, and carpet-cleaning professionals throughout Maryland, the law's carpet-cleaning implications begin at the product level and extend into every contract, equipment pad, and chemistry choice made on a job site.
Carpet-Cleaning Industry Implications: The Core Issue for Maryland Operators
Maryland's carpet-specific prohibition under Environment Article § 6-1604.1 is unequivocal: on or after January 1, 2024, a person may not manufacture, knowingly sell, offer for sale, or distribute for sale or use in Maryland any rug or carpet to which PFAS chemicals have been intentionally added. The statutory definition of "rug or carpet" is notably broad: it encompasses commercial or residential broadloom carpet, and critically, a pad or underlayment used in conjunction with a carpet — the only U.S. state law that explicitly includes padding and underlayment in its carpet-PFAS prohibition.
For carpet-cleaning operators, this creates three direct practical obligations. First, rotary-scrubber pads and bonnets incorporating PFAS-based fibers or stain-release treatments must be verified PFAS-free. Second, encapsulation chemistries that deposit a fluoropolymer crystalline structure for soil encapsulation — a common technology in commercial carpet maintenance — fall within the fabric-treatment category and are prohibited. Third, carpet-protection application services using fluorotelomer-based stain guards (C6 or C8 chemistry) cannot apply PFAS-containing protectant to new-installation carpets sold after January 1, 2024, as those carpets must themselves be PFAS-free; re-applying PFAS defeats the purpose of the law and may constitute a separate distribution violation.
The certificate of compliance requirement under § 6-1604.1(c) requires carpet manufacturers to establish a certificate of compliance attesting PFAS-free status and to provide it to the Maryland Department of the Environment (MDE) within 30 days of any request. Cleaning operators who purchase carpet for installation accounts should confirm a manufacturer's COC before procurement to avoid inheriting a compliance liability.
Full Scope of HB 275: The George "Walter" Taylor Act
Beyond carpets, HB 275 establishes three concurrent prohibitions effective January 1, 2024:
- Class B firefighting foam: Use, manufacture, knowing sale, or distribution of Class B fire-fighting foam containing intentionally added PFAS is prohibited. Limited exceptions apply for airports, ports, refineries, and chemical plants (through September 30, 2024); terminals (through December 31, 2027); and facilities governed by applicable federal law.
- Rugs and carpets: Manufacture, knowing sale, or distribution of rugs or carpets with intentionally added PFAS is prohibited. Second-hand rugs and carpets are explicitly exempt. Certificate of compliance required within 30 days of MDE request.
- Food packaging and disposable gloves: PFAS-containing food packages composed substantially of paper or plant-derived materials, and plastic disposable gloves used in commercial or institutional food service, are prohibited. Affects janitorial crews servicing food-service accounts.
A 2024 amendment (signed May 9, 2024) added a prohibition on playground surfacing materials containing PFAS effective October 1, 2024. For cleaning operators servicing school facilities or recreational venues, this affects field-maintenance and surface-care product selection near playgrounds.
The 2028–2029 Expansion: Consumer Products and Textiles
The Maryland General Assembly considered SB 686 / HB 1022 in 2026, which would significantly expand the PFAS prohibition schedule. Under this framework:
- January 1, 2028: Prohibition on cleaning products, cookware, cosmetics, personal care products, children's items, feminine hygiene products, and certain packaging containing intentionally added PFAS.
- January 1, 2029: Prohibition on textiles, fabric treatments, upholstered furniture, and paint containing intentionally added PFAS; any covered product not registered with MDE is prohibited regardless of PFAS status.
The expansion also includes a mandatory product-registration requirement: manufacturers of products containing intentionally added PFAS must register with MDE by January 1, 2028 and pay a registration fee deposited into a new Maryland PFAS Chemicals Protection and Remediation Fund. Beginning January 1, 2029, no manufacturer may sell a covered product unless it complies with registration, PFAS disclosure form, and fee requirements — creating a pre-market registry analogous to California's DTSC Safer Consumer Products program.
Penalty Structure and MDE Enforcement
Maryland's penalty framework under Title 6, Subtitle 16 of the Environment Article:
| Violation Type | Maximum Penalty |
|---|---|
| Carpet/rug prohibition (per violation) | Civil penalty up to $500 |
| Administrative penalty for carpet/rug violation | Up to $2,500 per violation; aggregate cap of $100,000 |
| General manufacturer violation of Subtitle 16 (proposed 2028 expansion) | Administrative penalty up to $15,000 |
| Violation of MDE administrative order | Civil penalty up to $25,000 per day of noncompliance |
| Willful violation by previously penalized party | Misdemeanor; fine up to $20,000 |
MDE enforces through its Compliance Program division. When MDE has reason to believe a product is being sold in violation, it may direct the manufacturer to provide testing results or a COC within 30 days. If testing confirms PFAS, the manufacturer must notify all Maryland retailers and buy back remaining prohibited stock. MDE enforcement contacts: phone 410-537-3314; email [email protected]; PFAS landing page — mde.maryland.gov PFAS.
AOC Textiles and Apparel Chemistry: The 2029 Horizon
The proposed 2029 expansion targets textiles, fabric treatments, and upholstered furniture — the categories most directly affecting the commercial cleaning supply chain. Area-of-concern (AOC) chemistries commonly used in commercial laundering and textile maintenance include fluorotelomer-based fabric conditioners, spray-on stain guards, and PFAS-releasing barrier coatings applied to tablecloths, aprons, and service textiles. Under the proposed Maryland framework, these will face prohibition in 2029 whether applied during manufacturing or during a cleaning service. Commercial laundry operators serving Maryland accounts should begin transitioning to non-fluorinated chemistry (fluorine-free DWR, silicone-based, or acrylate alternatives) in 2025–2026 — the 12–18 month product-qualification cycle means the 2029 deadline requires action now.
Compliance Actions for Maryland Cleaning Operators
- Confirm carpet COC before procurement: Require the manufacturer's certificate of compliance under MD Environment Art. § 6-1604.1 before purchasing any carpet or pad for installation accounts. Retain the COC for the life of the installation contract.
- Reformulate encapsulation products: Transition from fluoropolymer encapsulants to non-fluorinated polymer alternatives (acrylics, polyurethanes) immediately. PFAS-based encapsulants have been prohibited in Maryland since January 1, 2024 as fabric treatments.
- Audit rotary-scrubber pads: Identify any PFAS-treated pad surfaces in rotary operations. Discard legacy PFAS-treated pads; require PFAS-free written confirmation from pad suppliers going forward.
- Verify food-service glove supply: The 2024 prohibition on PFAS-containing plastic disposable gloves in commercial food service directly affects janitorial crews working food-service accounts. Confirm PFAS-free glove inventory.
- Track the 2028/2029 expansion: Monitor MDE PFAS updates and notify key cleaning-product suppliers of the approaching 2028 registration deadline under SB 686/HB 1022 if enacted.
- Communicate the padding provision to installation partners: Many flooring contractors are unaware that the Maryland prohibition extends to carpet padding and underlayment. Verify that all installed carpet systems are fully compliant before providing services based on PFAS-free representations.
Bid-Template Language and Primary Sources
"All cleaning products, carpet-care products, fabric treatments, and textile goods supplied or used under this agreement comply with Maryland's PFAS Chemicals Prohibitions under Environment Article, Title 6, Subtitle 16, as enacted by Chapter 138 (George 'Walter' Taylor Act, HB 275 / SB 273, 2022) and any successor amendments. Supplier certifies that no carpet, rug, or carpet padding supplied contains intentionally added PFAS chemicals as defined by Maryland law, and that a Certificate of Compliance under § 6-1604.1 is on file and will be provided to MDE upon request within 30 days. Supplier will notify Buyer within 14 days of any product becoming subject to a new Maryland PFAS prohibition."
Primary references: Maryland HB 275 bill text — mgaleg.maryland.gov HB 275 (2022); MD Environment Code § 6-1604.1 — Justia MD Environment § 6-1604.1; SGS summary — SGS Maryland PFAS Consumer Goods; 2026 SB 686 fiscal note — mgaleg SB 686 Fiscal Note; NCSL — NCSL PFAS State Legislation; EWG — EWG PFAS Chemicals.
Primary sources
- Maryland HB 275 — George "Walter" Taylor Act
- Maryland Environment Code § 6-1604.1 (Justia)
- MDE PFAS Landing Page
- SGS — Maryland PFAS Consumer Goods
- Maryland SB 686 Fiscal Note (2026 expansion)
- NCSL — PFAS State Legislation
- EWG — PFAS Chemicals
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.