What Will Chemical Legislation Look Like in US States in 2025?
Nearly three dozen US state legislatures are expected to consider a total of more than 300 bills this year addressing chemical policy, according to an environmental group that monitors state actions.
State legislatures have undertaken a high level of activity around chemicals regulation in recent years. With the second Trump administration pushing for deregulation at the federal level, the pace of state-level action is expected to continue in 2025.
On 5 February, Safer States released its annual analysis forecasting the number of state bills it expects to see this year that address chemicals like per- and polyfluoroalkyl substances (PFAS), formaldehyde, phthalates and others.
Legislators in at least 32 states are expected to consider a total of 340 or more bills to address chemicals at various stages of their lifecycles, the NGO said.
While many of the bills in the Safer States analysis cover wastewater and cleanup, analysis by Enhesa shows some 200 active bills focused on chemicals in products (see ‘Enhesa analysis’ box).
Most bills do not get signed into law, and none of the legislation introduced to this point has made it to a governor’s desk. Nevertheless, the spate of early activity around chemicals suggests a busy year ahead for state legislators.
State legislators this year have so far focused heavily on bills to limit PFAS, according to the latest information from Enhesa’s Legislation Tracker data tool.
The class of persistent chemicals has been mentioned in 65 bills introduced as of 19 February.
That pace parallels the level of activity in 2024, when more than a third of all bills introduced in US state legislatures addressed PFAS in some form or another.
Other than PFAS, lead is mentioned most often in proposed state legislation, with 15 bills. Mercury (13 mentions), phenols (12), formaldehyde (11), cadmium (8), toluene (7) and phthalates (7) are also seeing significant attention in statehouses.
Personal care products have seen the most legislative activity of any product sector so far in 2025. There are currently at least 42 bills proposing regulation of PFAS or other chemicals in personal care and cosmetic products.
Other consumer items and sectors mentioned in bills introduced so far this year include:
packaging (mentioned in 38 bills);
building materials and furnishings (27);
food contact materials (FCMs) (27);
recycling (24);
electronics (23); and
textiles and clothing (19).
New Jersey’s legislature has been the most active this year, with 52 chemical-related bills under consideration. Eight of those are carried over from the state’s 2024 legislative session.
PFAS are also a focus in New Jersey, with different bills looking to restrict PFAS in menstrual products, packaging, cosmetics, carpets, single-use plastic products, fabric treatments and FCMs.
Meanwhile, lawmakers in neighbouring New York have introduced at least 40 bills, including several seeking to add additional PFAS restrictions to those already on the books (see ‘Empire State’ box).
Other active state legislatures include Illinois (21 chemical bills), Washington (10), Maryland (9), Virginia (9), Texas (8) and Hawaii (8).
PFAS at the forefront
According to Safer States, at least 16 state legislatures are expected to consider bills to phase out some or all non-essential uses of PFAS or require disclosures for their presence in products.
This includes states that have historically been active, such as California, Maine, Minnesota, Oregon and Washington. But other states could also consider PFAS legislation, including Montana, New Mexico and Nevada, according to the Safer States analysis.
As in previous years, product categories being targeted for PFAS reductions include:
cosmetics and personal care products;
juvenile products;
cleaning products;
clothing and textiles;
FCMs;
firefighting foam and equipment;
cookware; and
artificial turf.
PFAS in firefighting foam and equipment
Reducing PFAS in firefighting materials promises to be a focus for many states in 2025. At least seven states – Connecticut, Maine, Montana, New Jersey, New York, Oregon and Pennsylvania – are considering policies to eliminate PFAS in firefighting foam, according to Safer States.
Proposals are expected to include phase-out plans, manufacturing restrictions and take-back programmes.
More than a dozen states have already moved to phase out PFAS in firefighting foams, and both the military and the Federal Aviation Administration (FAA) have previously been directed by Congress to stop using PFAS-based foams.
But PFAS foams may still be used in many states, particularly at airports or industrial facilities, according to Safer States. Thus, without a blanket federal restriction on PFAS-based foams, states are picking up the slack.
Another six states – Alaska, Illinois, Montana, New Jersey, Rhode Island and South Dakota – are considering policies that would phase out PFAS or require its disclosure for use in personal protective equipment (PPE), Safer States said.
Those bills call for either manufacturing restrictions or earmarking resources to pay for PFAS-free gear once safer alternatives become available.
Proposed PPE legislation tilts the other way, too. In California, for example, a Republican Assemblymember has introduced a bill (AB 333) that would exempt materials used to manufacture law enforcement uniforms from the state’s law prohibiting PFAS in clothing and textiles.
Formaldehyde and phthalates in personal care products
At least 14 states may consider policies that restrict the use of chemicals such as formaldehyde and phthalates in cosmetics, especially in products targeted to women of colour.
Menstrual products are another category where there could be legislative action, with at least ten states eyeing legislation to require the disclosure of chemical ingredients or prohibit the use of certain substances in menstrual products, the NGO said.
In Maine, for example, legislators may resubmit a bill (LD 1908) that was under consideration last year to restrict the use of formaldehyde releasers and other chemicals in cosmetic products, according to Sarah Woodbury, vice president of policy and advocacy for NGO Defend Our Health.
The latest version of the bill "is a good first step" in tackling chemicals of concern but excludes parabens and several ortho-phthalates that NGOs would like to see addressed, Woodbury said.
If the bill moves forward this legislative session, it "definitely needs to be strengthened at some point", she said.
Chemicals in packaging
Packaging promises to be another focus area in 2025.
At least 14 states are likely to consider legislation to reduce the use of plastics in packaging, while another six states may consider bills to restrict specific chemicals in FCMs, according to Safer States.
A New Jersey bill (S 3398) known as the Packaging Product Stewardship Act would create an extended producer responsibility programme for packaging similar to one in Maine.
Several states may also introduce legislation to phase out "the most problematic types" of plastic, including PVC and polystyrene, Safer States said. Some of those bills could look to formalise voluntary industry commitments made as part of the US Plastics Pact, according to the NGO.
Finally, at least four states – Alaska, California, Michigan and Rhode Island – may consider policies to restrict intentionally added microplastics in household cleaners and cosmetics.
Bills in these states could build on federal action banning plastic microbeads in rinse-off cosmetics and potentially harmonise standards with microbead legislation pursued in the EU, the NGO said.
Busy year in the Empire State
In New York, legislators have introduced a series of new PFAS-related bills already this year.
Among them are a bill (S 1548) to restrict PFAS and other substances in menstrual products, which passed the state Senate on 21 January and is progressing through the state Assembly.
Other New York bills include a measure to ban PFAS in various household products (S 187A), and another aimed at restricting PFAS, phthalates and heavy metals in cosmetics (S 2057).
State Senator Brad Holyman-Sigal (D), who sponsored the household goods bill, said he wants to remove intentionally added PFAS from products sold in the state "once and for all".
"After years of progress targeting specific industries, it’s time to pass our legislation to phase out the sale of a wide range of products containing intentionally added PFAS," Holyman-Sigal said.
Other New York bills target PFAS in bandages (A 1430) and PFAS and other "high concern" chemicals in pet food (A 1976).
Impact of Trump 2.0
For stakeholders trying to plan for the year ahead, it remains to be seen whether President Trump’s second administration will embolden states to accelerate their efforts.
A flood of state-level energy did follow the first Trump inauguration in 2016. However, the pace did not considerably let up when Democrats took over the White House in 2020.
"Regardless of who is in charge here in Washington, you see states moving ahead," American Chemistry Council (ACC) president Chris Jahn told journalists at a recent media briefing. "We did not see [Biden’s term] stop states from acting."
States have actively pursued chemical legislation across presidential administrations, and the ACC expects that to continue under the second Trump term.
"We all know who the states are," Jahn said, citing California, Washington, Minnesota, Maine and Oregon among those most active. "Wherever the issues are, that’s where we play."
Even so, some NGOs see the potential for federal inaction as a reason to redouble their efforts.
Andria Ventura, the legislative and policy director for Clean Water Action California, said the threat of Trump-backed federal cuts already has the NGO urging lawmakers in Sacramento to act.
"States have really been leading all along by making the first forays into regulating and mitigating the impacts of toxic chemicals like PFAS," Ventura said. That is "more important than ever", after the Trump administration spent its first month halting pending regulations and suggesting further rollbacks in the future.
"It is now totally up to our state to protect its residents from both inaction on the part of the federal government and potential attempts to overturn our protections," Ventura said.