Hawaii PFAS Food Packaging Law (Act 152): What Businesses Need to Know

Hawaii Act 152: An Overview

Hawaii enacted House Bill 1644, now Act 152, on July 12, 2022, restricting PFAS in specified plant-fiber food packaging types. The law took effect on December 31, 2024, making Hawaii one of the later states to reach the enforcement stage among those that legislated early.

Hawaii's law is narrower in scope than some other state bans — it applies to specific categories of plant-fiber packaging (wraps, liners, plates, food boats, and pizza boxes) rather than all plant-fiber packaging or all food packaging. Businesses in Hawaii should pay attention to which packaging types fall within the statute and which do not, to avoid both over-compliance cost and under-compliance risk.

Enforcement is handled by the Hawaii Department of Health (DOH) under HRS §321-602. For context on how Hawaii compares to other states, see our complete guide to PFAS food packaging bans in 2026.

Regulation Details

What Packaging Is Covered

Hawaii's Act 152 explicitly names the following plant-fiber packaging types as covered:

• Wraps and liners — paper and fiber-based food wrapping materials used in sandwich, burger, and deli service
• Plates — molded fiber or paper plates used in food service
• Food boats — open-top fiber containers used for fries, hot dogs, and similar foods
• Pizza boxes — corrugated or molded fiber boxes used for pizza delivery and takeout

What Is Not Covered

Hawaii's Act 152 does not cover packaging categories not explicitly listed in the statute, nor does it extend to non-plant-fiber materials. As a result, plastic clamshells, foam containers, aluminum foil packaging, and molded fiber clamshells (as distinct from plates and food boats) fall outside this specific law.

Food businesses in Hawaii using a mix of packaging types should carefully identify which products fall within the statute's enumerated list and which do not. It is advisable to seek legal guidance on the precise scope of coverage for your specific packaging inventory.

Penalties for Non-Compliance

Hawaii's Act 152 establishes a tiered penalty structure enforced by the Department of Health:

• First offense: up to $5,000
• Subsequent offenses: up to $10,000

Like other states, liability falls on manufacturers and distributors rather than food service operators. A restaurant that purchases non-compliant wraps from a supplier is not directly liable under Act 152, but the supplier faces enforcement action. Supply chain disruption risk — having to quickly source replacement compliant products — is a practical concern for food businesses regardless of where formal legal liability sits.

Common Steps Businesses Take

1. Map your packaging to Hawaii's covered categories. Review your packaging inventory and identify which products fall into the enumerated categories: wraps, liners, plates, food boats, and pizza boxes. Focus compliance review on these specific items.
2. Request compliance documentation from suppliers. For each covered packaging type, ask your supplier for a Certificate of Compliance or Certificate of Analysis confirming no intentionally added PFAS. Request total organic fluorine (TOF) test results where available.
3. Consider compliance documentation for all plant-fiber packaging. Even for packaging types not explicitly listed in Act 152, obtaining PFAS compliance documentation from suppliers is a best practice that positions your business well for future regulatory changes.
4. Maintain documentation records. Keep supplier correspondence, COAs, and test data organized. This evidence of due diligence is valuable both for regulatory purposes and for customer inquiries.
5. Monitor for future expansion. Hawaii may broaden Act 152 in future legislative sessions to cover additional packaging types or materials. Staying ahead of these changes reduces the need for urgent supply chain pivots.