If your US plan is “wait for FDA to ban PFAS”, you will miss Illinois, and you already missed earlier state dates. Keep a state grid next to the federal report.
Members Enforcement lesson
US
US PFAS: FDA wrote a data-gap report; states are writing bans
Owner takeaway
Inventory intentionally added PFAS now — that is the FDA report’s scope and most state laws’ scope.
Do not quote the FDA report as a green light in a retailer portal.
Illinois is a 2028 horizon in the bill text; other states already flipped in 2025. Confirm each statute.
If you sell nationwide on a marketplace, design to the strictest state you cannot geofence.
Why this now
FDA report (Dec 2025) plus Illinois HB 3409 (2026).
Who is affected
US marketplace sellers and anyone using fluorinated film-formers.
What to do
Monitor
Chaptered state acts; FDA PFAS cosmetics page.
Prepare
A SKU × state grid for intentional PFAS.
Act
Reformulate or geofence before the earliest state date you cannot miss.
Analysis
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Sources & related
Linked news
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