Maryland PFAS Legislative Update

Maryland's 2026 legislative session included significant discussion of per- and polyfluoroalkyl substances (PFAS), continuing a broader trend of increased state regulatory proposals regarding these chemicals. Of particular concern was proposed legislation, SB 686 and HB 1022, which included sweeping reporting and registration requirements covering equipment and component parts.

As introduced, the legislation would have required manufacturers to register products containing PFAS, raising immediate questions for the equipment manufacturing industry due to complex supply chains and the presence of PFAS in internal components and industrial applications. AEM engaged early and consistently, providing testimony before the Senate Education, Energy, and the Environment Committee, the House Health Committee, and the House Health Disparities Subcommittee. AEM also focused on educating lawmakers about the operational challenges of applying consumer product-style reporting requirements to complex equipment.

During the legislative process, bill sponsors indicated a willingness to adjust the proposal in response to stakeholder feedback. Discussions included removing the broad registration requirement and clarifying exemptions for internal components and paints-changes that would have addressed most concerns raised by AEM. However, these changes were not formally adopted before the March 23 crossover deadline, and the bill was set aside for further committee review without final action. While this effectively concludes PFAS-related legislative activity for this session in Maryland, it should not be viewed as a resolution. Policymakers remain committed to advancing PFAS-related reporting frameworks, and revised legislation is likely to be introduced early in the next session.

Compared to other state proposals, Maryland's PFAS approach is notable for its breadth and its attempt to apply registration requirements to complex equipment and component parts-not just consumer goods. As introduced, the bill raised concerns given its potential reach into industrial equipment and the lack of clear exemptions. In contrast, states like Maine and Minnesota largely focus on consumer products and intentionally added PFAS, often with clearer exemptions and phased timelines. New Mexico has enacted a comprehensive product law with reporting beginning in 2027 and phased prohibitions, including defined exemptions and a "currently unavoidable use" standard. Other states, such as Arizona, are focused more on groundwater contamination, remediation funding, and liability than product-based reporting. Overall, these approaches underscore a fragmented policy landscape in which states regulate PFAS either at the point of exposure or upstream at the product level, requiring manufacturers to track a patchwork of compliance obligations.

Looking ahead, AEM staff will continue to engage with state lawmakers and monitor PFAS-related developments closely as attention shifts toward 2027 state sessions. In Maryland, PFAS registration requirements are expected to reappear, likely with revisions and companion legislation in both chambers. Early engagement will again be essential to ensure that future legislative text appropriately reflects the realities of PFAS in the equipment manufacturing industry.

AEM will provide updates as new information becomes available and stands ready to support members in navigating this rapidly developing policy landscape.