Maine PFAS Law (LD 1503): Phase 1 in 2026, Then the Broadest PFAS Ban in the US
Maine LD 1503: An Overview
Maine enacted LD 1503 on July 15, 2021, setting the stage for one of the most expansive PFAS regulatory frameworks in the United States. The law operates in two phases: a near-term food packaging restriction and a sweeping long-term ban that covers virtually all products sold in the state.
Phase 1 takes effect on May 25, 2026, banning PFAS in plant-fiber food packaging. This aligns Maine broadly with other states like California, Colorado, and Maryland, though Maine's effective date is later than most.
Phase 2 is where Maine stands apart from every other US state: effective January 1, 2032, Maine will ban intentionally added PFAS in all products sold in the state — not just food packaging, but cookware, textiles, electronics, carpets, furniture, cosmetics, and more. This is the broadest PFAS law in the US by a significant margin.
For a comparison across all US states, see our complete guide to PFAS food packaging bans in 2026.
Regulation Details
ME LD 1503 (2021)
- May 25, 2026 — Phase 1: Ban on PFAS in plant-fiber food packaging
- January 1, 2032 — Phase 2: Ban on PFAS in ALL products (broadest US law)
All food packaging + coatings, inks, and adjacent items
Phase 1 (May 25, 2026): PFAS banned in plant-fiber food packaging. Phase 2 (2032): PFAS banned in ALL products sold in Maine — the broadest PFAS ban in the US.
Civil: up to $100 per violation
Up to $100 per violation under Title 32 Sec. 1736 (each package is a separate violation). General DEP enforcement under Title 38 may provide additional penalties. Enforced by Maine DEP.
Exemptions
- Products where PFAS use is deemed a currently unavoidable use (DEP determination required)
- Phase 1 exempts non-plant-fiber packaging
Phase 1: Plant-Fiber Food Packaging (May 2026)
Maine's Phase 1 restriction covers food packaging made from plant-fiber materials — molded pulp, paper, bagasse, bamboo, and similar plant-derived materials. This is the same category targeted by California, Colorado, Maryland, and Hawaii, though those states' effective dates were earlier.
Plant-fiber packaging covered under Phase 1 includes:
- Molded fiber clamshells, bowls, and plates
- Paper cups, bags, and wraps
- Pizza boxes (plant-fiber)
- Fiber trays and food boats
- Bagasse and bamboo fiber containers
If your business sources plant-fiber food packaging from suppliers who sell into the Maine market, the Phase 1 deadline of May 25, 2026 is approaching. Supplier compliance reviews should be underway now, as lead times for switching packaging suppliers and obtaining compliance documentation can run 3–6 months for some product categories.
Phase 2: All Products (January 2032)
Maine's 2032 phase is unlike anything currently enacted at the US state level. Beginning January 1, 2032, Maine will prohibit the sale of any product containing intentionally added PFAS. The scope extends well beyond food packaging to encompass virtually every consumer and commercial product category:
- Cookware and kitchen equipment with PFAS-based coatings
- Food-contact packaging of all materials (plastic, foam, foil)
- Textiles and upholstery
- Carpets and rugs
- Cosmetics and personal care products
- Electronics and electrical components
- Outdoor gear and clothing
For food businesses, the 2032 phase means that PFAS-containing kitchen equipment, cookware, and non-fiber packaging sold or used in Maine will eventually need to be replaced. Planning for this transition, even while Phase 1 is the immediate priority, is advisable for businesses with a long-term presence in the Maine market.
The “Currently Unavoidable Use” Exemption
Maine's law includes an important exemption for PFAS uses that are determined to be “currently unavoidable.” A manufacturer may petition the Maine Department of Environmental Protection (DEP) to have a specific PFAS use classified as unavoidable, which would allow continued use of that product in the state beyond the applicable deadline.
This exemption exists because there are some industrial and commercial applications where genuinely effective PFAS alternatives do not yet exist. The exemption is not automatic — it requires a DEP determination and is intended to be a limited, time-bound provision as alternatives continue to develop. Food businesses selling into Maine should not rely on this exemption for common packaging types, where PFAS-free alternatives are widely available.
Penalties for Non-Compliance
Maine's LD 1503 carries penalties of up to $100 per violation under Title 32, Section 1736, with each non-compliant product package treated as a separate violation. Maine DEP also has general enforcement authority under Title 38, which may provide additional penalty avenues.
While $100 per package sounds modest, the per-package structure means that penalties can scale significantly for distributors shipping large volumes of non-compliant packaging. Enforcement is handled by the Maine DEP.
Maine's penalty structure differs from most other states, which charge per-day or per-violation fees of $500 to $15,000. Maine charges $100 per package treated as a separate violation. For a distributor shipping pallets of non-compliant containers, this could mean penalties in the thousands even at $100 per unit.
Common Steps Businesses Take
- Prioritize Phase 1 now. The May 25, 2026 plant-fiber packaging deadline is imminent. Conduct supplier compliance reviews for all molded fiber, paper, and bagasse packaging without delay.
- Request Certificates of Compliance from plant-fiber suppliers. Ask for written documentation confirming no intentionally added PFAS, and for total organic fluorine (TOF) test results where available.
- Begin longer-term planning for Phase 2. Even though 2032 is years away, businesses that use PFAS-containing cookware, textiles, or other products in their Maine operations should begin tracking which items will require replacement.
- Document your compliance efforts. Maintain organized records of supplier correspondence, compliance certificates, and test data for both phases of the law.
- Monitor DEP guidance and rulemaking. Maine DEP will issue guidance and rules as the Phase 2 deadline approaches. Staying informed ensures your business is not caught off guard by implementation details.
The information in this guide is provided for educational purposes only. It does not constitute legal advice. PFAS regulations are evolving and the specific facts of your situation may affect how these laws apply to your business. Consider consulting with a qualified attorney or compliance professional for guidance tailored to your circumstances.
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