Vermont PFAS Restrictions on Cleaning Products — Act 131

By the Opora Editorial Team

Vermont's PFAS regulatory program is the clearest example in the nation of how a small state with limited market power can use methodical, product-class-by-product-class legislation to move manufacturers on a national scale. Rather than enacting a single sweeping ban, Vermont has progressively layered restrictions across years — firefighting foam and food packaging in 2021, rugs, carpets, and ski wax in 2023, then the landmark Act 131 (S.25) signed in May 2024 covering cosmetics, cookware, textiles, artificial turf, and juvenile products, and most recently Act 54 (H.238) signed June 11, 2025, extending the framework to cleaning products, dental floss, and fluorinated containers. This architecture — statute by statute, product class by product class — is deliberate: it creates rolling compliance obligations that keep manufacturer reformulation pressure constant. For commercial cleaning operators serving Vermont businesses, the critical question is always: which product class are we on, and when is the next deadline?

From Act 36 to Act 131 to Act 54: Vermont's Legislative Lineage

Vermont's PFAS framework traces its origin to S.20 (Act 36 of 2021), which banned PFAS in Class B firefighting foam (effective July 1, 2022), food packaging, residential rugs and carpets, and ski wax (all effective July 1, 2023). Act 131 (S.25 of 2024), which took effect in phases beginning July 1, 2024, consolidated and dramatically expanded coverage, as UL Solutions confirms. Act 131 is codified in Title 9 (Commerce and Trade) and covers: aftermarket stain and water-resistant treatments; artificial turf; cookware; cosmetics and menstrual products; incontinency protection products; juvenile products; residential rugs and carpets; ski waxes; textiles and textile articles; Class B firefighting foam; and personal protective equipment. It simultaneously repealed the prior Act 36 framework effective January 1, 2026, creating a single unified statute.

The 2025 expansion — Act 54 (H.238) — extends restrictions to cleaning products, dental floss, and fluorinated treated plastic containers effective July 1, 2027, and adjusts several deadlines, including pushing the cookware ban from January 2026 to July 1, 2028. The full updated schedule is available from SGS's Vermont regulatory update.

Cleaning Products Ban: July 1, 2027

Act 54 defines "cleaning products" as compounds intended for routine cleaning, including general-purpose cleaners and hand soaps. Effective July 1, 2027, no person may manufacture, sell, offer for sale, distribute for sale, or distribute for use in Vermont any cleaning product to which PFAS have been intentionally added. This is the restriction most directly impactful to commercial cleaning operators and covers the full spectrum of cleaning chemistry — surface sprays, degreasers, hand soaps, tile and grout cleaners, and all-purpose concentrates formulated with fluorinated surfactants for improved wetting, soil release, or stain penetration. Fluorinated surfactants are used in commercial cleaning formulations precisely for their performance benefits — Vermont's Act 54 definition of "intentionally added" captures exactly this functional use. Operators must begin requesting PFAS disclosures from cleaning chemistry suppliers now and planning transitions to fluorine-free alternatives.

Textile Articles: The 50 ppm TOF Standard

Under Act 131, textiles and textile articles containing intentionally added PFAS are prohibited effective July 1, 2027. Vermont's standard is technically distinctive: the ban applies when regulated PFAS (a) have been intentionally added to provide a functional or technical effect, or (b) are present at or above 50 parts per million total organic fluorine (TOF). This dual-test approach means that even a product whose manufacturer claims no intentional PFAS addition will trigger a violation if TOF testing detects fluorine above that threshold — the burden effectively shifts to documented testing.

For commercial cleaning operators, textile articles cover microfiber cleaning cloths, mop heads, flat-mopping pads, and wiping rags with DWR or stain-resistant coatings. The 50 ppm TOF measurement standard aligns with California's AB 1817 framework and will likely become the de facto industry testing benchmark. Operators should request TOF test results from all textile suppliers before the July 2027 deadline.

Firefighting PPE: Notice Requirements Now, Restriction in 2029

Act 131 takes a staged approach to firefighting PPE. As of July 1, 2025 — a requirement already in effect — manufacturers of firefighter station wear (uniform shirts and pants worn beneath structural PPE) must provide written notice to purchasers if the garments contain intentionally added PFAS. Then, effective July 1, 2029, the full PPE category faces an outright prohibition on intentionally added PFAS — including structural firefighting jackets, pants, gloves, helmets, boots, and respiratory equipment. Respirators receive a further extension to July 1, 2032. Commercial cleaning companies that launder or supply firefighter uniforms should request manufacturer PFAS disclosures for all station wear immediately.

Vermont Attorney General: Consumer Protection Enforcement

Vermont's PFAS product restrictions are enforced by the Vermont Attorney General through the state's Consumer Protection Act (9 V.S.A. § 2453). A violation of the PFAS product statutes is deemed a violation of the CPA, giving the AG authority to investigate, issue civil penalties, pursue injunctive relief, and enter assurances of discontinuance. Retailers who sell prohibited products are within scope — not just manufacturers. As VTDigger reports, Act 131 also directed state agencies to explore pre-market product screening — the possibility of requiring PFAS-free certification before a covered product can enter Vermont commerce — signaling a future shift from reactive enforcement toward proactive supply-chain screening.

The AG may request compliance certificates from manufacturers. Within 60 days, a manufacturer must either certify compliance or notify all in-state sellers that the product's sale is prohibited and submit a list of those sellers to the AG. This 60-day window is tighter than in many other states and should factor into documentation protocols.

Phase-by-Phase Compliance Timeline

Documentation and Certifications

Vermont's certification mechanism is AG-triggered rather than a mandatory pre-market filing. Best-practice documentation includes: a manufacturer PFAS declaration letter identifying the product and covered category; TOF test results from an accredited laboratory (especially for textiles: below 50 ppm TOF); a no-intentionally-added-PFAS attestation signed by an authorized official; and the date of certification. Retain documentation for at least three years from date of sale. Vermont's Department of Health has co-developed consumer guidance with the AG's Office available at the Vermont Department of Health PFAS page.

Compliance Checklist and Bid-Template Language

1. Immediately review cleaning chemistry: request fluorinated surfactant disclosures from all cleaning product manufacturers before the July 1, 2027 ban.
2. Audit textile inventory: request TOF test results for microfiber cloths, mop heads, and wiping rags; confirm below 50 ppm TOF before July 1, 2027.
3. Station wear disclosures: request manufacturer PFAS notices for all firefighter station wear now (July 1, 2025 obligation already in effect).
4. Prepare 60-day certification response capability: build documentation systems able to respond to AG certification requests within the statutory window.
5. Monitor cookware and PPE deadlines: begin transitioning food-service cookware recommendations to PFAS-free ahead of July 1, 2028; audit structural firefighting PPE for July 1, 2029.
6. Update procurement contracts: align PFAS-free warranty language with the phase-in schedule above.

Recommended bid clause: "All cleaning products, textile articles, mop heads, and fabric treatments supplied under this agreement shall comply with Vermont Act 131 (S.25 of 2024) as amended by Act 54 (H.238 of 2025), codified under 9 V.S.A. Chapter 63, containing no intentionally added PFAS. For textile articles, vendor shall provide TOF testing confirming total organic fluorine below 50 ppm. Vendor shall respond to Vermont AG compliance certification requests within 60 days. Cleaning product formulas must be PFAS-free by July 1, 2027."

For the official Act 131 text, see the Vermont Legislature's Act 131 document (PDF).

Primary sources

• Vermont Legislature — Act 131 As Enacted (PDF)
• UL Solutions — Vermont Signs S.25 (Act 131)
• SGS — Vermont Revises Law on PFAS in Products (Act 54, 2025)
• VTDigger — House Bill Would Add Floss and More to Vermont PFAS Regulations
• Vermont Department of Health PFAS Page
• Beveridge & Diamond — Vermont Enacts PFAS Restrictions
• National Sea Grant Law Center — Vermont PFAS Legal Provisions (PDF)

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.