New Mexico’s PFAS In-Products Rule: Compliance Requirements Begin January 1, 2027

New Mexico’s PFAS In-Products Rule, which took effect July 1, 2026, will reach its first major compliance deadline on January 1, 2027. Beginning on that date, the state will prohibit the sale or distribution of certain products containing intentionally added per- and polyfluoroalkyl substances (PFAS), including cookware, food packaging, dental floss, juvenile products, and firefighting foam.

Manufacturers and suppliers subject to the rule must also submit their PFAS in-products initial reports by January 1, 2027. Through advocacy efforts by the RV Industry Association, the Rule includes important exemptions that significantly reduce reporting obligations for the RV industry. These exemptions cover motorhomes, towable RVs, qualifying motor vehicle equipment, certain HVAC and refrigeration equipment, and products containing specified fluoropolymers. Additional exemptions may apply to certain electrical equipment and components. For a more complete list of reporting exemptions, go to: Prohibitions in PFAS in consumer products

You can request a waiver from reporting in New Mexico if you have reported substantially equivalent information into another publicly available database, such as PRISM in Minnesota. Waivers are subject to the New Mexico Environment Department’s (NMED) approval, and requests must be submitted by December 2, 2026. Waiver requests are made through the New Mexico PFAS Reporting System (NMPRCS).

Regarding the Rule’s separate labeling requirements in New Mexico, on September 16, 2026, a Federal District Judge approved a preliminary injunction blocking New Mexico from enforcing its labeling requirements while litigation is ongoing to determine the constitutionality of the labeling mandate.

Additional information and Frequently Asked Questions (FAQs) about the PFAS In-Products Rule are available at the NMED website for manufacturers, which provides detailed instructions and guidelines about registration, reporting, waivers, labeling, and fees. The RV Industry Association also held a webinar about the January 1, 2027, manufacturing deadline, which can be viewed here (members only; login required).

For more information about this issue, please contact Bill Erny, Senior Manager of Regulatory Affairs, at Berny@rvia.org.