California adopts restrictions on PFAS treatments for textiles or leather


The California Department of Toxic Substances Control (DTSC) has adopted a proposal to regulate as a priority product under the Safer Consumer Products regulations.

The proposal covers treatments containing perfluoroalkyl or polyfluoroalkyl substances for use on processed textiles or leather. As a result, manufacturers of goods subject to sale in California must submit a Priority Product Notification (PPN) for their goods by 31 May. After submitting the PPN, manufacturers will have the option of submitting one of the following by 28 September:

  • a notification of intent/confirmation of removal of chemicals;
  • a notification of intent/confirmation of removal of the product;
  • a notification of intent/confirmation of substitution of the chemical in the product;
  • a preliminary report analysing alternatives or other reporting options.


A priority product list will apply to any PFAS-containing product placed on the market in California that could be marketed or sold for the purpose of

  • removing dirt or stains from carpets, clothing, shoes, upholstery, or other processed textiles and leathers
  • resist stains, dirt, oil, or water from carpets, clothing, shoes, upholstery, or other processed fabrics and leathers.


This includes cleaners, protectors, stain removers and waterproofing or water repellents, but does not include products marketed or sold exclusively for use during the production of carpets, rugs, clothing, shoes, upholstery or other processed textiles and leather.


The Safer Consumer Products Regulations require the various operators involved (manufacturers, importers, assemblers and retailers) to notify DTSC when their product is listed as a priority product.


Manufacturers or other entities responsible for products listed as priority products are required to perform an ‘alternative analysis’ for the product and the chemicals of concern it contains to determine how best to limit exposures or the level of adverse impact on public health and the environment. DTSC is also required to identify and require implementation of regulatory responses to protect public health and/or the environment and maximise the use of acceptable and feasible alternatives of lesser concern.


DTSC has the authority to require regulatory responses for a priority product (if the manufacturer chooses to retain the priority product) or for an alternative product selected to replace the priority product. This may include the requirement to remove or replace the chemical in question in the product or the removal of the product from the California marketplace. To date, sleeping products filled with children’s foam containing tris(1,3-dichloro-2-propyl)phosphate (TDCPP) or tris(2-chloroethyl)phosphate (TCEP), polyurethane spray foam systems with diphenylmethane diisocyanate, carpets and rugs containing PFAS, paints containing methylene chloride, and PFAS treatments for processed textiles or leather have been listed as priority products.



Author: Patrizia Lombardini

International Technical Dept. Manager