Initially aimed at firefighting foams, Illinois’ PFAS Reduction Act (SB 2516) was passed on August 6, 2021. The Act forbade the manufacturing, sale, and distribution of class B firefighting foam that contained purposefully added per- and polyfluoroalkyl substances (PFAS) starting on January 1, 2025, and the use of such foam for training or testing starting on January 1, 2022.

The Act’s scope was greatly expanded on August 15, 2025, when HB 2516 was passed. The amendment, which will go into effect on January 1, 2032, forbids the sale, offer for sale, or distribution of dental floss, cosmetics, menstruation products, juvenile items, and intimate clothing that contains purposefully added PFAS.

Affected Product Categories

The 2032 ban will apply to the following:

· Cosmetics: Products intended to be applied to the human body for cleansing, beautifying, or altering appearance, including soap.

· Dental Floss: Defined as a cord of thin filaments for interdental cleaning.

· Intimate Apparel: Garments usually worn with direct skin contact, such as bras, boxers, briefs, shapewear, sleepwear, thermals, loungewear, socks, and stockings.

· Juvenile Products: A broad category of items designed for children under 12, including crib mattresses, strollers, highchairs, and car seats. However, it does not cover adult mattress, children’s electronics, and internal components of a product that do not come into direct contact with a child’s skin or mouth.

· Menstrual Products: This encompasses items like tampons, pads, menstrual cups, and menstruation underwear.

Exemptions

The legislation includes several key exemptions. The ban will not apply to:

· Goods where state jurisdiction is superseded by federal law.

· The selling or reselling of second-hand goods.

· Internal or electronic parts of goods.

· Certain foams, aerosol propellants, and refrigerants that are permitted under the Significant New Alternatives Policy (SNAP) program of the U.S. Environmental Protection Agency, unless they are utilized in personal care products.

Penalties for Non-Compliance

The State’s Attorney of the county in which the infraction occurs, or the Illinois Attorney General will enforce the Act. Non-compliance carries civil fines of up to $5,000 for the first infraction and up to $10,000 for each further infraction. The Environmental Protection Trust Fund will receive all fines collected under the Act.

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