New Mexico Hosts PFAS Labeling Requirements Webinar

Update:

Beginning January 1st, 2027, manufacturers and producers of PFAS products must have a PFAS label on their
product being sold in New Mexico. Unless they have an approved label waiver for their product from the New
Mexico Environment Department (NMED). A labeling waiver is available to manufacturers and producers that are
exempt from the PFAS prohibition and that can demonstrate that no consumer will come into direct contact with
any PFAS while the HVACR product is being used as intended. A labeling waiver must be submitted by October 31st, 2026, to be considered by NMED. Note, the labeling requirement is for manufacturers and producers, but
distributors may want to contact their manufacturer to ask about their PFAS labeling plans if you do business in
New Mexico.

For clarification and additional information, the NMED has updated its website in recent months to help
manufacturers, producers, and other supply chain stakeholders understand their PFAS labeling requirements. To
better understand the manufacturer's obligation for PFAS labeling, you can click here and visit the manufacturers
tab of the PFAS site. Additionally, NMED has provided a PDF guidance document to condense the necessary
information. You can view the labeling guidance summary PDF here.

HARDI will continue to update this blog post, and members will be notified as relevant New Mexico PFAS labeling
updates are shared.

Originally Posted 10-1-2025:

On September 25th, the New Mexico Environment Department hosted a webinar about their upcoming rules for labeling requirements for products containing PFAS. In the 2025 Legislative Session, New Mexico lawmakers passed and Gov. Michelle Lujan Grisham signed House Bill 212 (HB212). HB212, the PFAS Protection Act, phases out consumer products with intentionally-added PFAS, and exempts heating, ventilation, air-conditioning, and refrigeration (HVACR) equipment and refrigerants, as long as the refrigerants are approved under the U.S. Environmental Protection Agency’s (EPA) Significant New Alternatives Policy (SNAP) program.

New Mexico is Developing Labeling Requirements for PFAS

Under the New Mexico Environment Department’s PFAS policy, all products containing PFAS must be labeled to inform consumers of its presence. The Department looks to have the labeling requirement begin on January 1, 2027. You can view the label requirements slides from the webinar here.

HVACR Industry is Eligible for Exemption from Labeling Requirements

The HVACR manufacturers are eligible to apply for exemption from the labeling requirements since the HVACR industry is exempt from the PFAS prohibition in HB212. Manufacturers will need to contact the New Mexico Environment Department to request the exemption and demonstrate that consumers of the HVACR product will not come into direct contact with any PFAS while the HVACR product is being used as intended and throughout the useful life of the product. As a distributor, you can verify the exemption with your manufacturer and confirm any labeling requirements that must then be placed on the HVACR products. This blog post will be updated as new information or industry-wide exemptions for labeling occur.

If you have any questions, please contact HARDI’s Director of State and Public Affairs, Todd Titus.

Follow Along for More HVACR State Issues

State regulations can evolve fast, and staying informed is key to staying compliant. Visit HARDI's State Issues page to explore the latest legislative and regulatory developments affecting the HVACR industry. Whether it’s the HFC phasedown or other state-led initiatives, this resource helps you track what matters most, where it matters most.