What Auto Component (and other) Manufacturers Need to Do Now

New Mexico is moving toward the broadest PFAS labeling regime in the country. If adopted, the rule would require labels on all products with intentionally added PFAS that are sold, offered for sale, or distributed in the state, with a blanket exemption only for used products. Labeling would begin January 1, 2027.

Below is a clear summary of what is in play, why it matters, and how to prepare.

The quick version

• Effective date: Labeling is slated to start January 1, 2027. New Mexico intends to release final label graphics after rulemaking concludes.
• Scope: Applies to all products with intentionally added PFAS sold or distributed in New Mexico. Used products are exempt. Complex durable goods (for example, motor vehicles or HVAC systems) will have distinct disclosure mechanics but similar content.
• Format: Labels must be conspicuous and durable and will link by web address or QR code to state information. For online and catalog sales, the disclosure must appear where the product is marketed. Labels must be in English and Spanish.
• Reporting tie-in: A product-level PFAS report is due January 1, 2027. Products that contain intentionally added PFAS and are not reported by January 1, 2028 cannot be sold in New Mexico.
• Bigger picture: New Mexico is also phasing out certain PFAS-containing products in 2027 and 2028, with a general prohibition on non-exempt PFAS products by 2032.

Where the rule stands

The New Mexico Environment Department (NMED) petitioned the Environmental Improvement Board on October 8, 2025 to initiate rulemaking under the state’s PFAS Protection Act. A public meeting followed on October 22, 2025. The hearing is expected in February or March 2026, after which the Board could adopt a final rule.

Several respected stakeholders have flagged this as potentially the first U.S. requirement to label all products with intentionally added PFAS, not just select categories.

Key requirements in plain language

1) Who must label

Any manufacturer of a product with intentionally added PFAS that is sold or distributed in New Mexico. For private-label goods, the manufacturer remains responsible unless a retailer agrees to take it on.

2) What must be labeled

All products with intentionally added PFAS, except used products. Complex durable goods (such as vehicles and HVAC systems) are covered, but the label or disclosure may appear in different ways compared to small consumer items.

3) How to label

• Conspicuous and durable label at point of purchase.
• Include a URL or QR code that directs consumers to state information on PFAS in products.
• For online and catalog sales, the disclosure must appear in product marketing materials.
• English and Spanish language requirement. NMED will provide standard graphics and approved language after the rule is finalized. There is no pre-approval requirement for label use.

4) Possible label exemptions

Two conditions are needed together:

1. The product fits a category exempt from reporting requirements, and
2. The manufacturer can demonstrate that consumers will not come into direct contact with intentionally added PFAS during intended use over the product’s useful life.

5) Reporting deadlines that affect sales

• Report due: January 1, 2027, for each product or component with intentionally added PFAS.
• Sales restriction: Starting January 1, 2028, any PFAS-containing product not reported cannot be sold in New Mexico.

6) Phase-out schedule you should know

• January 1, 2027: Cookware, food packaging, dental floss, juvenile products, and firefighting foam.
• January 1, 2028: Carpets and rugs, cleaning products, cosmetics, fabric treatments, textiles and textile furnishings, feminine hygiene products, ski wax, upholstered furniture.
• January 1, 2032: Remaining non-exempt products without a “currently unavoidable use” designation.

7) Consistency with other states

NMED has indicated that manufacturers may satisfy New Mexico labeling by complying with a corresponding labeling regime in another state, once established, and by providing NMED the required information. This is meant to limit duplicative work.

What this means for different sectors

• Consumer products and electronics: Expect product-by-product assessments, SKU-level label planning, and online disclosure integration.
• Automotive, industrial equipment, HVAC: Labeling or disclosure will likely need to surface in manuals, on packaging, or at point of sale. Some components may qualify for a label exemption if there is no consumer contact, but that needs proof.
• Private-label and marketplace sellers: Clarify who owns labeling duties and build processes to ensure disclosures appear in listings.

A realistic prep checklist

1. Map your product portfolio sold into New Mexico. Identify where PFAS are intentionally added at the component and material levels. Link this to SKUs and packaging types.
2. Confirm reporting data you must submit by Jan 1, 2027 and build the data pipeline that will populate those submissions.
3. Design label placement for packaging and for online disclosures. Reserve space for the QR code or URL. Plan for English and Spanish copy.
4. Evaluate exemptions where appropriate. For example, certain categories or internal-only uses with no consumer contact may qualify. Document your rationale and evidence.
5. Coordinate with suppliers to verify material declarations and obtain PFAS attestations.
6. Audit marketing systems so PDPs, spec sheets, and catalogs carry the disclosure on January 1, 2027.
7. Watch the hearing timeline and any edits to the proposed rule. The Board hearing is targeted for February or March 2026, and NMED will release final label graphics after rule adoption.

Timing is tight

The rule is still proposed, but the clock has started. NMED’s materials make clear there is no plan to extend the January 1, 2027 labeling date, and reporting is also due by that date. Companies that wait until late 2026 will be scrambling to redesign packaging, update ecommerce templates, and stand up reporting.

Why this is likely the first of its kind

Other states are advancing PFAS policies, but New Mexico’s approach to labeling every product with intentionally added PFAS is unusually broad. That is why many trade groups and law firms are tracking this closely and advising early engagement.

If you want help interpreting how this rule applies to your products, mapping your portfolio, sorting out labeling vs. exemption decisions, and building a practical plan for 2026 changes, TKD² Group LLC can help. We can assess your obligations, create a product-level labeling and reporting plan, and prepare you for the 2027 start date and later phase-outs.

Let’s talk. We’ll help you get in front of this, minimize risk, and plan for downstream impacts.

#Automotive #AutomotivePlastics #Plasticinjectionmolding #labelling #PFAS

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