Two PFAS labels can look pretty similar sitting on a packing table.
One says “Contains PFAS.”
The other says “Contains PFAS in Internal Components.”
It might be tempting to choose whichever phrase fits the package better and move on. Unfortunately, product compliance rarely lets us off that easily.
The right label starts with the product, not the sticker. A company first needs to confirm whether PFAS were intentionally added, where they are located, which state rules apply, and whether the selected wording accurately describes the product.
The label communicates the decision. It does not make the decision for you.
This article reflects Connecticut information available in August 2026. It is not legal advice. PFAS requirements can change, so businesses should review current agency guidance and consult qualified counsel when needed.
What Is the Difference Between the Two PFAS Labels?
Connecticut’s Department of Energy and Environmental Protection, commonly called DEEP, currently lists both phrases among its approved PFAS disclosures:
- Contains PFAS
- Contains PFAS in Internal Components
Both phrases tell the purchaser that PFAS are present. The second provides additional context about where the PFAS-containing part is located.
When Might “Contains PFAS” Fit?
“Contains PFAS” is a short, general disclosure. It may fit when a company has confirmed that a covered product contains intentionally added PFAS and determines that a straightforward statement accurately communicates the required notice.
Its compact wording can work well on smaller packages or crowded information panels, but available space should not be the only reason it is chosen.
When Might “Contains PFAS in Internal Components” Fit?
“Contains PFAS in Internal Components” gives the purchaser more specific information. It may fit when the PFAS-containing material is located within an internal component of a larger finished product and the company confirms that the phrase accurately describes the product.
Connecticut law says that when one of the covered products containing intentionally added PFAS is a component of another product, the product containing that component must be labeled.
That does not mean businesses should automatically use the internal-components phrase every time an unseen part is involved. The company responsible for compliance should confirm that the wording is accurate and appropriate for the particular product.
Do Not Choose the Friendlier-Sounding Phrase
“Contains PFAS in Internal Components” may sound more limited than “Contains PFAS,” but that is not a reason to select it.
Likewise, the shorter phrase should not be chosen simply because it is easier to fit beside a barcode.
Ask a few basic questions first:
- Has the company confirmed that PFAS were intentionally added?
- Is the PFAS present throughout the product, on a surface, or within a component?
- Does “internal components” accurately describe its location?
- Is the product covered by the rule?
- Where will the product be manufactured, distributed, offered, or sold?
- Has the final wording been reviewed by the person responsible for compliance?
If those answers are still fuzzy, it is too early to start applying labels.
What Does Connecticut Require?
Beginning July 1, 2026, Connecticut requires specified product categories containing intentionally added PFAS to meet notification and labeling requirements before being manufactured, sold, offered for sale, or distributed for sale in the state.
The covered categories currently include:
- Apparel
- Carpets and rugs
- Cleaning products
- Cookware
- Cosmetic products
- Dental floss
- Fabric treatments
- Juvenile products
- Menstruation products
- Textile furnishings
- Ski wax
- Upholstered furniture
Separate requirements apply to outdoor apparel for severe wet conditions and firefighter turnout gear.
Connecticut requires the purchaser-facing label to:
- Be clearly visible before the sale
- Use words or symbols approved by DEEP
- Inform the purchaser that PFAS are present
- Remain legible for the product’s useful life when affixed to the product
Businesses can review the current approved wording, covered categories, reporting information, exemptions, and agency updates on the official Connecticut DEEP PFAS in Products page. The complete requirements appear in Connecticut General Statutes Section 22a-903c.
How Do You Confirm Which Label to Use?
1. Start With Product and Supplier Information
Review supplier declarations, product specifications, bills of material, chemical information, testing records, and other reliable documentation available to the company.
Connecticut DEEP has stated that the labeling trigger is intentional addition, not merely detecting a trace amount of PFAS. Do not apply a disclosure just because PFAS might be present or because similar products sometimes contain them.
2. Identify Where the PFAS Are Used
Determine whether PFAS are used in a coating, treatment, exterior material, internal part, membrane, lubricant, finish, or another component.
This step helps the company decide whether a general statement or the more specific internal-components wording accurately describes the product.
3. Check Every Sales Market
PFAS rules are not identical across the country. Another state may have different covered products, deadlines, exemptions, disclosure language, reporting obligations, or placement requirements.
A phrase approved in Connecticut should not be treated as a universal PFAS label for every market.
4. Approve the Wording Before Production
The regulatory, legal, product, or quality person responsible for the decision should approve the exact phrase before rolls are placed at packing stations.
Documenting the decision also helps purchasing, production, warehouse, and fulfillment teams use the correct label on the correct item.
Where Should the PFAS Label Be Placed?
Connecticut focuses on visibility before the sale rather than naming one placement that works for every product.
A cookware box, cosmetic container, carpet roll, cleaning-product bottle, jacket tag, and piece of furniture all present different problems.
Possible locations include:
- A visible side or back panel of retail packaging
- Near other material or ingredient information
- Beside the barcode without covering it
- On a product tag or hangtag that remains visible
- Directly on an unpackaged product when the surface is suitable
Do not place the sticker inside sealed packaging, underneath the product, behind another label, or where a customer would only find it after completing the purchase.
A label on a master shipping carton may help warehouse employees, but it may not provide notice to the final purchaser after the product is removed from that carton.
Test the Sticker Before Labeling the Entire Run
This is the unglamorous step that can prevent a very glamorous mess later.
Apply the label to the actual product or package and check:
- Whether the surface is clean and dry
- Whether the full message is easy to read
- Whether the purchaser can see it before sale
- Whether the adhesive bonds to the material
- Whether handling causes the edges to lift
- Whether heat, moisture, oil, bending, texture, or abrasion affects it
- Whether it covers other required information
A label that performs well on a smooth paperboard carton may behave differently on flexible plastic, coated metal, fabric packaging, a curved container, or a textured product.
Permanent adhesive is not a magic spell. The actual label, surface, placement, and conditions still need to be tested together.
What Does the Sticker Not Replace?
Applying the right disclosure does not finish the entire PFAS process.
Depending on the rule and product, a company may still need to complete:
- Manufacturer notification or reporting
- Supplier and chemical documentation
- Certificates of compliance
- Online or written disclosures
- Internal approval and quality records
- Reviews for other states or sales markets
Connecticut also describes a broader prohibition beginning January 1, 2028 for the listed product categories containing intentionally added PFAS, subject to the law’s exemptions and details. A disclosure label used during the current phase should not be treated as permanent permission to continue selling the product indefinitely.
What Are PFAS?
PFAS are a large group of manufactured chemicals used in consumer, commercial, and industrial products. The U.S. Environmental Protection Agency explains that many PFAS break down very slowly and that thousands of different PFAS chemicals exist.
For a plain-language overview, visit the EPA’s PFAS Explained page.
Choose the Wording First, Then Choose the Label
The difference between “Contains PFAS” and “Contains PFAS in Internal Components” is not simply one inch of label space.
One provides a general disclosure. The other adds information about the PFAS being in internal components. The right choice depends on accurate product information, current requirements, the markets where the item will be sold, and the company’s compliance review.
ChromaLabel offers both PFAS disclosure label options: 1-inch square Contains PFAS labels and 1 x 2 inch “Contains PFAS in Internal Components” labels. Each roll contains 500 black-on-white labels made in Kansas, USA, for application to suitable clean, dry surfaces.
Confirm the product. Approve the wording. Test the placement. Then apply the label as one clear part of the larger process.
