PFAS Food Packaging Bans by State: What Restaurants, CPG Brands, and Packaging Buyers Need to Know

Twelve states have banned intentionally added PFAS in food packaging. If you sell, source, or manufacture food-contact packaging, here is what that means for your business. This post covers which states have active bans, what they require, when they took effect, what the penalties are for non-compliance, and what PFAS-free alternatives exist today. If you want the broader context on what PFAS are and why regulators acted, our post on PFAS in packaging covers the science, health evidence, and regulatory history in depth. You don't have to figure this out alone.

One quick note before we get into it: PS curates supplier information from publicly available sources and supplier submissions. We don't independently verify every claim — that's your job as the buyer, and we'll tell you exactly how to do it. Throughout this post we flag the specific questions to ask, the certifications to look for, and the tests to request. Use this as your preparation guide, not your final answer.

Which States Have Banned PFAS in Food Packaging?

As of April 2026, twelve states have enacted laws restricting intentionally added PFAS in food packaging or food service ware, with scope varying by material type and use case: California, Colorado, Connecticut, Hawaii, Maine, Maryland, Minnesota, New York, Oregon, Rhode Island, Vermont, and Washington. These state-level laws operate alongside the FDA's confirmation in 2024 that manufacturers have completed a voluntary phase-out of PFAS-based grease-proofing agents used in paper and paperboard food packaging, and these uses are no longer being supplied into the U.S. market.

State bans remain critical even after the FDA phase-out because they are broader in product scope, they include ongoing enforcement frameworks, and in many cases they set testing thresholds such as total organic fluorine limits that go beyond simple supplier attestation. The result is a regulatory patchwork that multi-state brands must navigate carefully.

State-by-State Overview

California: AB 1200 bans intentionally added PFAS in plant-fiber food packaging including molded fiber bowls, plates, and clamshells, effective January 1, 2023. The law also sets a 100 ppm total organic fluorine threshold used as a compliance screening level. Enforcement is handled by state prosecutors with civil penalties available under California's Health and Safety Code and related enforcement statutes.

Colorado: HB22-1345 prohibits PFAS in food packaging made of paper, paperboard, or plant fiber, effective January 1, 2024. The statute authorizes the Attorney General to enforce and impose civil penalties.

Connecticut: Public Act 21-191 restricts intentionally added PFAS in food packaging, effective December 31, 2023. The law subjects violations to civil penalties, with higher exposure for knowing violations or false certifications, which can trigger criminal liability under the state's broader toxics-in-packaging enforcement framework.

Hawaii: Act 152 (2022) restricts PFAS in specified plant-fiber food packaging types including wraps, liners, plates, food boats, and pizza boxes, effective December 31, 2024.

Maine: A rule adopted in April 2024 implements Maine's statutory PFAS prohibition for defined plant-fiber food packaging categories under the state's broader PFAS-in-products law, effective May 25, 2026, with limited exemptions including for uses designated as "currently unavoidable" under state law. Maine's framework is among the most expansive, moving toward near-total PFAS prohibition across product categories.

Maryland: The George "Walter" Taylor Act (SB 273, 2022) bans intentionally added PFAS in certain direct food-contact paper and paperboard packaging components, effective January 1, 2024.

Minnesota: Statute 325F.075 prohibits the manufacture, sale, or distribution of food packaging with intentionally added PFAS, effective January 1, 2024. The Minnesota Pollution Control Agency enforces the statute and has published guidance clarifying that both manufacturers and downstream sellers can be held responsible.

New York: Environmental Conservation Law Article 37, Title 2 bars intentionally added PFAS in plant-fiber food packaging, effective December 31, 2022. State guidance expects manufacturers, distributors, and retailers to maintain certificates of compliance and provide them to the New York Department of Environmental Conservation on request.

Oregon: SB 543 prohibits food vendors and wholesalers from using or selling food service ware containing intentionally added PFAS, starting January 1, 2025. Violations carry per-day civil penalties.

Rhode Island: The state's PFAS food packaging ban took effect January 1, 2025, after the original 2024 effective date was extended.

Vermont: Act 36 (S.20, 2021) prohibits intentionally added PFAS in food packaging, effective July 1, 2023.

Washington: RCW 70A.222 restricts intentionally added PFAS in defined paper and plant-fiber food packaging categories. The first wave of restrictions took effect February 1, 2023, following Washington Department of Ecology alternatives assessments that identified safer options for wraps, liners, plates, food boats, pizza boxes, bowls, containers, and bags. Identifying safer alternatives is a prerequisite for restriction under Washington state law, making those assessments the regulatory foundation for the bans.

What the Bans Actually Cover

The core prohibition is straightforward: you cannot sell, distribute, or in some states use covered food packaging that contains intentionally added PFAS. "Intentionally added" means the manufacturer deliberately included PFAS to confer a specific characteristic such as grease resistance or moisture barrier performance, as opposed to trace contamination from recycled content or manufacturing processes.

Importantly, not all states define food packaging the same way. Some laws apply broadly to all food packaging materials, while others are limited to paper, paperboard, or plant-fiber items, meaning flexible plastic packaging such as snack bags may not be covered. Minnesota and Vermont use broader definitions that can reach CPG packaging. California and New York limit their bans to plant-fiber packaging. Oregon applies restrictions specifically to food service ware used by vendors and wholesalers, not retail consumer packaging.

Covered formats across most states typically include molded fiber bowls and clamshells, paper wraps and sandwich liners, pizza boxes, greaseproof paper bags, and compostable plates. Flexible plastic films and multilayer chip bags are generally outside the scope of current state bans except in the broadest-definition states.

If you are sourcing recyclable pizza boxes, compostable takeout containers, compostable clamshell containers, or paper takeout boxes, PFAS compliance is a direct procurement question you should be asking every supplier before placing an order.

Penalties for Non-Compliance

Enforcement mechanisms and penalty structures vary by state. Active enforcement actions have been limited so far, but the legal frameworks are fully in place and the exposure is real for brands that can't demonstrate compliance.

California authorizes civil penalties under California's Health and Safety Code and related enforcement statutes. The California Attorney General has issued warnings emphasizing that companies must disclose PFAS presence and comply with AB 1200.

Connecticut subjects violations to civil penalties, with higher exposure for knowing violations including submitting a false certificate of compliance, which can trigger criminal liability under the state's toxics-in-packaging enforcement framework.

Oregon sets clear per-day penalties: $100 per day for food vendors and $500 per day for wholesalers who sell or use PFAS-containing food service ware after January 1, 2025. That creates a predictable and escalating cost for continued non-compliance.

Colorado authorizes the Attorney General to enforce the prohibition and pursue civil penalties under the Act's broader enforcement provisions.

Minnesota's Pollution Control Agency can pursue administrative penalties and injunctive relief, and has clarified that both manufacturers and downstream sellers can be held responsible.

Even in states where penalty amounts are not codified in the statute itself, enforcement typically includes the ability to seek injunctive relief stopping sales, corrective action including product recalls, and reimbursement of investigation costs. For a brand selling in multiple states, a single non-compliant SKU can trigger parallel enforcement actions in several jurisdictions simultaneously.

Effective Dates at a Glance

Already in effect: New York (December 31, 2022), California (January 1, 2023), Washington (February 1, 2023 for initial categories), Vermont (July 1, 2023), Connecticut (December 31, 2023), Colorado, Maryland, and Minnesota (January 1, 2024), Hawaii (December 31, 2024), Oregon and Rhode Island (January 1, 2025). Coming soon: Maine (May 25, 2026 for specified plant-fiber categories).

If you are ordering packaging today, specify PFAS-free regardless of your ship date. The FDA's voluntary phase-out means PFAS-treated grease-proofing papers have effectively exited the U.S. supply chain, and state bans provide the legal backstop. Treat this as a settled transition rather than something still in progress.

PFAS-Free Alternatives That Already Exist

The good news is that state regulators did the work to identify safer alternatives before imposing bans. Washington's Department of Ecology conducted rigorous alternatives assessments and concluded that feasible, safer substitutes are available for wraps, liners, plates, food boats, pizza boxes, bowls, containers, and bags. Those findings provided the regulatory justification for phased restrictions and they reflect real commercial availability, not aspirational technology.

PFAS-free barrier technologies now in commercial use include aqueous coatings (water-based dispersions that create grease and moisture barriers), bio-based coatings derived from plant starches or proteins, silicone-based barriers, and mechanical densification of fiber which reduces porosity without chemical treatment. Many suppliers have reformulated their molded fiber and paper packaging lines entirely and are pursuing third-party certifications to verify the change.

Performance trade-offs do exist and are worth understanding before switching. PFAS-free alternatives can have slightly higher material costs, typically in the range of 10 to 30 percent depending on format and volume, and in some cases reduced shelf life for high-fat or high-moisture products. But for the majority of takeout and food service applications including pizza, sandwiches, baked goods, salads, and dry snacks, commercially available PFAS-free packaging performs adequately when matched to the product and storage conditions. Our sustainable foodservice packaging page covers the full landscape of compliant formats and suppliers across these categories. For bakery applications specifically, sustainable bakery packaging covers the formats most relevant to grease-resistant paper and fiber formats.

How to Verify Your Packaging Is PFAS-Free

Most state agencies recommend and in some cases require that buyers obtain a manufacturer Certificate of Compliance affirming that the packaging contains no intentionally added PFAS. New York DEC's guidance is explicit: manufacturers, distributors, and retailers subject to the ban must maintain certificates and provide them to the agency on request.

A credible certificate should include the product description and SKU, a statement that no PFAS were intentionally added during manufacturing, and ideally a reference to supporting test data or third-party certification. From a risk management perspective, attestation alone may not be sufficient — independent testing adds a meaningful verification layer.

The most common independent screening test is total organic fluorine analysis, typically conducted via combustion ion chromatography. California's 100 ppm TOF threshold has become a de facto industry benchmark. BPI certification requires both a no-intentionally-added-PFAS declaration and a TOF result of 100 ppm or less for compostable packaging products. That dual standard of attestation plus test result offers stronger assurance than either element alone.

One important note: do not rely on X-ray fluorescence screening for PFAS compliance. XRF detects elemental fluorine but cannot distinguish between PFAS and other fluorinated compounds. TOF via combustion ion chromatography is widely used for compliance screening and certification purposes and is the method referenced in California's guidance and BPI's certification standard.

Building a PFAS-Free Packaging Specification

If you are writing or updating a packaging spec to comply with state bans, include these elements. State explicitly in your purchase order terms that no PFAS were intentionally added, using the phrase "intentionally added PFAS" which matches state statutory language rather than vague terms like "PFAS-free" or "eco-friendly." Specify a total organic fluorine limit of 100 ppm or less for paper and plant-fiber packaging, measured via combustion ion chromatography by an accredited lab. Require a signed certificate of compliance with each shipment or at minimum on file and updated annually, referencing the specific product SKU and lot. Request recent TOF test reports typically within the past 12 months or evidence of BPI or GreenScreen Certified status. If you distribute in California, New York, Washington, or other states with active bans, note those jurisdictions in your spec and confirm the supplier understands the applicable requirements.

This approach mirrors how New York DEC and California DTSC describe compliance expectations in their published guidance and creates an audit trail that demonstrates good-faith compliance efforts.

The Bottom Line

PFAS bans in food packaging are the regulatory reality in twelve U.S. states right now, with enforcement frameworks, penalty structures, and documentation requirements fully in place. The compliance path is clear: specify no intentionally added PFAS, require a 100 ppm TOF limit for paper and plant-fiber packaging, obtain certificates of compliance with supporting test data, and document everything. Waiting for a state agency to initiate contact is not a compliance strategy. It is also worth noting that several states are expected to expand PFAS restrictions beyond food packaging into broader product categories between 2026 and 2030, making enterprise-wide PFAS compliance planning increasingly important for any brand operating across multiple categories.

The brands ahead of this have already had the conversation with their suppliers and updated their specs. If you haven't yet, that is the next conversation to have. Our sustainable foodservice packaging page covers the formats and suppliers best positioned to help you make that transition. For specific formats, recyclable pizza boxes and compostable takeout containers are good starting points depending on your category.

Sustainable packaging can be complicated, but we are here to change that. If you already know what you need, our free search tool gets you there fast. If you want to explore what's out there, our sustainable packaging suppliers directory covers companies across every format and category. And if you'd rather have us help you find the right fit, get in touch and we'll point you in the right direction.