On March 23, the New Mexico Environmental Improvement Board (EIB) voted to finalize labeling requirements for products sold or distributed in the state that contain intentionally added PFAS. These requirements will go into effect on January 1, 2027, and apply to RVs manufactured on January 1, 2027, or later. The move aims to increase transparency and accountability among manufacturers of recreational vehicles (RVs) regarding the presence of these substances in their products.
The required label will consist of an Erlenmeyer flask containing the word “PFAS.” For complex durable goods, such as RVs, the label is not required to appear on the product itself but must be included in a consumer-facing product specification sheet and the operation and maintenance manual. This distinction highlights the need for clear communication between manufacturers and regulators.
The label must be legible, no less than 10-point font, and must be approved by the New Mexico Environment Department prior to application. The emphasis on readability underscores the importance of accessibility in product labeling, particularly for consumers who may not have a technical background.
During the rulemaking proceedings, the RV Industry Association (RVIA) submitted written comments and provided testimony explaining the challenges associated with collecting PFAS information on component parts across a diverse, global supply chain. The association's advocacy played a crucial role in shaping the final labeling requirements.
As a result of the RV Industry Association’s advocacy efforts during the legislative process, RVs are exempt from the reporting requirements and the total product ban, which is slated for January 1, 2032. This exemption acknowledges the complexity of global supply chains and the need for flexibility in regulatory frameworks.
The Environmental Improvement Board is currently making formatting and other nonsubstantive changes to the text of the rule, which is expected to be released to the public in May 2026. The RV Industry Association will provide a thorough analysis of the final rule as soon as it becomes available. Further compliance guidance will be made available once the final rule is published.
The implementation of PFAS labeling requirements marks an important milestone in the ongoing effort to regulate these substances in the United States. As the regulatory landscape continues to evolve, manufacturers and consumers alike must remain vigilant and adapt to changing standards.
While some may view the introduction of PFAS labeling requirements as a burdensome compliance task, it is essential to recognize the potential benefits for public health and environmental protection. By promoting transparency and accountability, these regulations can help mitigate the risks associated with PFAS exposure.
As the RV industry continues to navigate this new regulatory landscape, it is crucial that manufacturers prioritize communication and collaboration with regulators and stakeholders. This approach will enable the development of effective solutions that balance competing interests and promote a safer, more sustainable future.
