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 Jan. 1, 2027, and apply to RVs manufactured on Jan. 1, 2027, or later.
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. The label must be legible, no less than 10-point font and must be approved by the New Mexico Environment Department prior to application.
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. As a result of the RV Industry Association’s advocacy, most of the initial labeling requirements were removed from the proposed rule, including listing each PFAS-containing component in the operation and maintenance manual, the association said. Further, RVIA emphasized that PFAS substances are used in internal components for performance and safety purposes, where alternatives are not currently available.
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 Jan. 1, 2032, RVIA said.
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.
For more information about this issue, please contact Bill Erny, RV Industry Association senior regulatory affairs manager, at [email protected].
