Kentucky has joined the growing number of states implementing comprehensive PFAS regulations, and manufacturers selling products into Kentucky markets face a critical compliance deadline on January 1, 2027. House Bill 196, signed into law and announced by the Kentucky Energy and Environment Cabinet (EEC) in January 2026, establishes mandatory reporting requirements for products containing intentionally added PFAS—creating immediate obligations for organizations across multiple industries.

For compliance leaders, product stewardship teams, and executive decision-makers, Kentucky PFAS compliance represents more than a state-level reporting requirement. It's part of an accelerating regulatory trend where states are independently implementing PFAS restrictions, reporting mandates, and phase-out timelines that require unified compliance infrastructure capable of tracking substance composition across product portfolios and managing multi-jurisdictional obligations simultaneously.

This comprehensive guide explains what changed under Kentucky HB 196, who must comply, critical reporting deadlines and data requirements, and how organizations can prepare for the January 1, 2027 reporting deadline while positioning for expanding PFAS regulatory obligations across other states.

Table of Contents

1. What Is Kentucky PFAS Regulation Under HB 196?

2. What Changed and Why Kentucky PFAS Compliance Matters Now

3. Who Must Comply: Industry-by-Industry Breakdown

4. Critical Dates and Kentucky PFAS Compliance Timeline

5. Reporting Requirements and Product-Level Data Expectations

6. Business Risks, Penalties, and Executive-Level Impact

7. Kentucky PFAS Compliance Action Checklist: What to Do Now

8. How Certivo Simplifies Kentucky PFAS Compliance

1. What Is Kentucky PFAS Regulation Under HB 196?

House Bill 196 establishes Kentucky's framework for addressing PFAS (per- and polyfluoroalkyl substances) in consumer and commercial products through a dual approach: mandatory manufacturer reporting and establishment of a PFAS Working Group tasked with studying health impacts and developing mitigation strategies.

Legislative Framework and Regulatory Authority

The Kentucky Energy and Environment Cabinet (EEC) administers HB 196, providing regulatory oversight and enforcement of PFAS reporting requirements. The legislation creates accountability for manufacturers while enabling state officials to understand PFAS presence in products sold within Kentucky markets.

Official source (Kentucky EEC): https://eec.ky.gov/Environmental-Protection/Pages/PFAS_Exposure.aspx

The PFAS Working Group Mandate

HB 196 establishes a PFAS Working Group responsible for:

• Studying health impacts of PFAS exposure on Kentucky residents

• Evaluating mitigation strategies to reduce PFAS contamination

• Developing policy recommendations based on scientific evidence

• Coordinating with state agencies on PFAS-related initiatives

The Working Group convenes its first meeting on September 1, 2026, and delivers its initial mitigation report by December 1, 2026—providing manufacturers insight into potential future restrictions or phase-out requirements beyond current reporting obligations.

Scope of Intentionally Added PFAS

Kentucky PFAS compliance focuses specifically on intentionally added PFAS—defined as PFAS deliberately incorporated into products where the manufacturer expects the substance to remain present in the final product. This definition distinguishes intentional use from incidental contamination or trace presence resulting from manufacturing processes.

The intentionally added PFAS standard means manufacturers must understand product-level substance composition and verify whether PFAS serves functional purposes in materials, coatings, treatments, or components rather than appearing only as unintended by-products.

2. What Changed and Why Kentucky PFAS Compliance Matters Now

New Reporting Obligations for Manufacturers

Prior to HB 196, Kentucky had no comprehensive PFAS reporting framework. The legislation creates mandatory disclosure requirements for manufacturers whose products contain intentionally added PFAS and are sold, offered for sale, or distributed in Kentucky.

This represents a fundamental shift from voluntary disclosure to legally mandated reporting with the January 1, 2027 deadline establishing the first compliance checkpoint.

Annual Reporting Creates Ongoing Obligations

Unlike one-time disclosure requirements, Kentucky PFAS compliance establishes annual reporting cycles. After the initial January 1, 2027 submission, manufacturers must file updated reports every January 1 thereafter, creating permanent compliance infrastructure requirements rather than project-based activities.

Strategic Importance Beyond Kentucky

Kentucky PFAS compliance matters beyond state borders because:

Multi-State Regulatory Acceleration - Kentucky joins California, Maine, Minnesota, Massachusetts, and other states implementing independent PFAS requirements. Organizations selling nationally must navigate multi-jurisdictional compliance frameworks with varying definitions, thresholds, and deadlines.

Supply Chain Visibility Requirements - State-level PFAS reporting demands detailed supply chain data that most manufacturers lack. Organizations discovering gaps in Kentucky compliance often identify systemic weaknesses affecting compliance readiness across multiple regulations.

Precursor to Restrictions - State reporting requirements frequently precede use restrictions or phase-out mandates. Kentucky's PFAS Working Group will use manufacturer reports to inform future policy recommendations, making current reporting accuracy critical to shaping reasonable future requirements.

Customer Compliance Pressure - Enterprise customers and retailers increasingly require PFAS compliance documentation from suppliers. Kentucky reporting creates verification demands that extend throughout supply chains.

Organizations treating Kentucky PFAS compliance as an isolated state requirement miss the strategic imperative to build scalable compliance infrastructure addressing the broader PFAS regulatory landscape.

3. Who Must Comply: Industry-by-Industry Breakdown

Kentucky PFAS compliance under HB 196 applies broadly across industries manufacturing or distributing products containing intentionally added PFAS:

Electronics and Electrical Equipment

PFAS appears in electronics manufacturing as:

• Circuit board coatings and laminates

• Wire and cable insulation

• Semiconductor processing chemicals

• Heat-resistant components

• Display technologies

Electronics manufacturers must assess PFAS presence in components, materials, and surface treatments across product portfolios to determine Kentucky PFAS reporting obligations.

Automotive and Transportation

The automotive sector uses PFAS extensively in:

• Brake fluids and hydraulic systems

• Fuel system components

• Weatherstripping and seals

• Interior fabric treatments (stain resistance)

• Underbody coatings

Automotive manufacturers and suppliers selling parts, accessories, or finished vehicles into Kentucky markets face reporting requirements for products containing intentionally added PFAS.

Textiles, Apparel, and Footwear

PFAS provides performance characteristics in textiles including:

• Water-resistant and stain-resistant treatments

• Outdoor and performance apparel

• Footwear materials and coatings

• Upholstery fabrics

• Protective workwear

Textile and apparel companies must verify whether fabric treatments, coatings, or finishes contain intentionally added PFAS requiring Kentucky reporting.

Medical Devices and Healthcare Products

Medical applications of PFAS include:

• Surgical gowns and drapes with fluid resistance

• Medical tubing and catheters

• Implantable devices with biocompatible coatings

• Dental floss and oral care products

• Pharmaceutical packaging

Medical device manufacturers must assess PFAS use in both device components and packaging materials to determine Kentucky PFAS compliance scope.

Cosmetics and Personal Care Products

PFAS appears in cosmetics as:

• Long-wear makeup formulations

• Sunscreens and moisturizers

• Shaving products

• Hair care treatments

• Nail polish

Cosmetics manufacturers face Kentucky PFAS reporting requirements if formulations contain intentionally added PFAS for performance benefits like water resistance or smoothness.

Food Packaging and Food Contact Materials

Food packaging commonly uses PFAS in:

• Grease-resistant paper and cardboard

• Non-stick coatings for cookware

• Take-out containers and wrappers

• Microwave popcorn bags

• Pizza boxes

Organizations manufacturing or distributing food packaging in Kentucky must report intentionally added PFAS in materials designed to resist oil, grease, or moisture.

Construction and Building Materials

Construction applications include:

• Weatherproofing membranes

• Paints and coatings

• Sealants and adhesives

• Roofing materials

• Insulation products

Construction material manufacturers must evaluate whether products contain PFAS for water resistance, durability, or other performance characteristics.

Consumer Goods and Household Products

Broad consumer product categories affected:

• Non-stick cookware

• Cleaning products

• Carpet and rug treatments

• Furniture with stain-resistant fabrics

• Pet products

Furniture and Home Furnishings

PFAS use in furniture includes:

• Upholstery stain treatments

• Carpet backing and treatments

• Mattress covers and bedding

• Outdoor furniture coatings

Chemicals and Plastics

Chemical manufacturers supplying PFAS substances or PFAS-containing formulations to other manufacturers face Kentucky reporting requirements even when not producing finished consumer products.

Industrial and Commercial Products

Industrial applications span:

• Lubricants and hydraulic fluids

• Industrial coatings

• Fire suppression systems

• Metal plating processes

• Cleaning and degreasing agents

The breadth of affected industries demonstrates that Kentucky PFAS compliance extends far beyond traditional chemical sectors, requiring cross-industry compliance approaches and supply chain verification programs.

4. Critical Dates and Kentucky PFAS Compliance Timeline

Kentucky PFAS compliance under HB 196 involves multiple milestones leading to the January 1, 2027 reporting deadline:

Understanding the January 1, 2027 Deadline

The January 1, 2027 deadline represents the first mandatory PFAS disclosure for manufacturers. Organizations must submit complete, accurate reports covering:

• All products containing intentionally added PFAS

• Products sold, offered for sale, or distributed in Kentucky during the reporting period

• Required data elements specified in HB 196

Timeline Implications for Compliance Preparation

With the January 1, 2027 deadline approaching, manufacturers face compressed timelines for:

Product Portfolio Assessment (3-4 months minimum)

• Inventory all products sold into Kentucky

• Identify products potentially containing PFAS

• Verify PFAS presence through supplier declarations or testing

• Determine whether PFAS is intentionally added

Supplier Data Collection (4-6 months typical)

• Engage suppliers to obtain PFAS declarations

• Validate supplier responses for accuracy and completeness

• Address data gaps through follow-up or testing

• Document due diligence efforts

Report Preparation and Submission (2-3 months)

• Compile required data elements for each affected product

• Verify accuracy of CAS numbers, quantities, and contact information

• Prepare submission documentation

• Submit reports by January 1, 2027 deadline

Organizations starting Kentucky PFAS compliance preparation in Q3 2026 or later face significant time pressure to meet the reporting deadline without automated compliance workflows accelerating data collection and validation.

PFAS Working Group Timeline and Future Implications

The September 1, 2026 Working Group meeting and December 1, 2026 mitigation report create transparency into potential future Kentucky PFAS requirements beyond current reporting obligations. Manufacturers should monitor Working Group recommendations to anticipate:

• Potential product category restrictions

• Phase-out timelines for specific PFAS uses

• Enhanced reporting requirements

• Testing or verification mandates

5. Reporting Requirements and Product-Level Data Expectations

Kentucky PFAS compliance under HB 196 requires manufacturers to submit detailed product-level disclosures containing specific data elements:

Required Reporting Data Elements

For each product containing intentionally added PFAS, manufacturers must report:

1. Product Description and Identification

• Product name and description

• Universal Product Code (UPC) if available

• Stock Keeping Unit (SKU) or manufacturer part number

• Product category classification

Accurate product identification enables Kentucky EEC to track PFAS presence across product types and assess exposure patterns.

2. Purpose of PFAS Use

• Functional role of PFAS in the product

• Performance characteristics PFAS provides (e.g., water resistance, stain resistance, non-stick properties)

• Justification for PFAS inclusion

This element requires manufacturers to articulate why PFAS is intentionally added rather than incidentally present, demonstrating understanding of product formulation and material composition.

3. Amount and Identity of PFAS

• Chemical Abstract Service (CAS) number for each PFAS substance

• Exact quantity of PFAS in the product OR

• Approved quantity range if exact amounts constitute confidential business information

Manufacturers must provide substance-specific data rather than generic "PFAS present" declarations. This requires detailed material composition databases tracking PFAS at the chemical level.

4. Manufacturer Contact Information

• Legal business name

• Physical address

• Telephone number

• Responsible party contact for compliance inquiries

Complete contact information enables Kentucky EEC to communicate with manufacturers regarding reports, request clarifications, or conduct compliance verification.

Defining "Intentionally Added PFAS"

The intentionally added PFAS standard focuses on deliberate inclusion where manufacturers expect PFAS to remain in the final product. This typically includes:

Clearly Intentional Uses:

• PFAS added as raw materials in formulations

• PFAS-containing treatments applied to substrates

• PFAS incorporated into component materials for functional purposes

• PFAS used in manufacturing processes that remain in finished products

Potentially Excluded Uses:

• PFAS appearing only as trace contamination in raw materials

• PFAS used in manufacturing equipment that does not contact products

• PFAS present only as unintended byproducts of chemical reactions

Manufacturers uncertain whether PFAS presence constitutes "intentionally added" should consult regulatory guidance or legal counsel to avoid reporting errors or omissions.

Data Quality and Verification Requirements

Kentucky PFAS reporting requires accurate, verifiable data. Manufacturers should:

Obtain Supplier Certifications Request written declarations from material and component suppliers documenting PFAS presence, identity, and quantities. Supplier declarations provide evidence supporting reported data.

Conduct Product Testing When supplier data is unavailable or unreliable, laboratory testing verifies PFAS presence and quantifies concentrations. Testing creates defensible data for Kentucky reporting.

Maintain Supporting Documentation Preserve supplier declarations, test reports, formulation records, and material specifications demonstrating basis for reported information. Documentation enables response to Kentucky EEC inquiries.

Implement Quality Control Verify reported CAS numbers are correct, quantities are accurate, and product descriptions match actual items sold in Kentucky. Data errors undermine report credibility and may constitute compliance violations.

Organizations lacking centralized substance data systems struggle to assemble accurate Kentucky PFAS reports from fragmented spreadsheets, supplier emails, and disconnected product databases.

6. Business Risks, Penalties, and Executive-Level Impact

While HB 196 establishes reporting requirements, non-compliance creates business risks extending beyond immediate regulatory penalties:

Regulatory Enforcement and Compliance Failures

Failure to submit required Kentucky PFAS reports by January 1, 2027 or submission of incomplete or inaccurate reports creates regulatory enforcement risk. While specific penalty amounts are not yet established in publicly available guidance, enforcement actions typically include:

• Required corrective action and resubmission

• Potential civil penalties for violations

• Increased regulatory scrutiny of future submissions

• Public disclosure of non-compliance

Market Access and Customer Requirements

Major retailers and enterprise customers increasingly require suppliers to demonstrate PFAS compliance before approving products for sale. Kentucky PFAS non-compliance can result in:

• Disqualification from retail partnerships

• Loss of customer contracts

• Product delisting from distribution channels

• Competitive disadvantage versus compliant suppliers

Organizations that respond faster to customer compliance inquiries gain preferred supplier status and maintain market access.

Supply Chain Disruption

Discovering PFAS compliance gaps during reporting preparation can trigger:

• Emergency supplier qualification efforts

• Product reformulation requirements

• Sourcing delays affecting production schedules

• Inventory obsolescence for non-compliant materials

Proactive compliance risk management identifies supply chain vulnerabilities before they create operational disruption.

Reputational and Brand Risk

Public PFAS reporting creates transparency regarding chemical use in products. Negative publicity surrounding PFAS presence can damage:

• Consumer brand perception

• Corporate environmental reputation

• Investor confidence in ESG commitments

• Employee morale and recruitment

Strategic Planning Implications

Kentucky's PFAS Working Group will use manufacturer reports to inform future policy recommendations. Current reporting accuracy influences:

• Reasonableness of future restrictions or phase-outs

• Feasibility assessments for PFAS alternatives

• Economic impact analyses for proposed regulations

• Industry-specific exemptions or extended timelines

Manufacturers providing incomplete or inaccurate data risk future regulations based on incomplete information that may impose unrealistic compliance burdens.

Executive Fiduciary Considerations

Board members and executive officers bear responsibility for environmental compliance risk management. Kentucky PFAS non-compliance that results in enforcement actions, market access restrictions, or reputational damage creates potential fiduciary concerns where adequate compliance systems were not implemented.

7. Kentucky PFAS Compliance Action Checklist: What to Do Now

Organizations subject to Kentucky PFAS reporting requirements should implement these compliance actions immediately:

☑ Conduct Comprehensive Product Portfolio Assessment

Inventory Kentucky Market Products:

• Identify all products sold, offered for sale, or distributed in Kentucky

• Prioritize high-volume products and product lines generating significant Kentucky revenue

• Include products sold through distributors or online channels reaching Kentucky customers

Assess PFAS Presence:

• Review product formulations, materials, and treatments for potential PFAS content

• Identify product categories with high probability of PFAS use (coatings, treatments, specialized materials)

• Flag products requiring supplier verification or testing

☑ Engage Suppliers for PFAS Declarations

Launch Systematic Supplier Engagement:

• Develop standardized PFAS declaration templates requesting required reporting data

• Distribute declarations to material, component, and chemical suppliers

• Establish response deadlines allowing adequate time for validation before January 1, 2027

• Track supplier response rates and implement follow-up protocols

Validate Supplier Data Quality:

• Review supplier declarations for completeness and accuracy

• Verify CAS numbers correspond to actual PFAS substances

• Confirm quantity data is provided in usable formats

• Request supporting documentation for significant PFAS quantities

☑ Conduct Product Testing Where Necessary

Identify Testing Needs:

• Products where suppliers cannot provide PFAS declarations

• High-risk products with uncertain PFAS status

• Products where supplier data conflicts or raises questions

Engage Qualified Laboratories:

• Select laboratories with validated PFAS testing methods

• Specify testing protocols appropriate for product matrices

• Request quantitative results enabling accurate reporting

☑ Implement Centralized Data Management

Consolidate PFAS Compliance Data:

• Replace spreadsheets with systematic compliance infrastructure providing single-source-of-truth visibility

• Link product data with supplier declarations and test results

• Enable reporting workflows generating Kentucky submissions from centralized databases

• Establish data governance ensuring ongoing accuracy

☑ Prepare Kentucky PFAS Reports

Compile Required Data Elements:

• Product descriptions and UPC/SKU identifiers

• PFAS purpose and functional justification

• CAS numbers and quantities for each PFAS substance

• Manufacturer contact information

Conduct Quality Control Review:

• Verify data accuracy and completeness

• Confirm all intentionally added PFAS products are included

• Validate CAS numbers and quantity data

• Review product descriptions for clarity

Document Supporting Evidence:

• Retain supplier declarations supporting reported data

• Preserve test reports validating PFAS presence and quantities

• Maintain records demonstrating due diligence in data compilation

☑ Submit Reports by January 1, 2027

Prepare for Submission:

• Understand Kentucky EEC submission procedures and format requirements

• Allocate resources for report preparation and review

• Submit well before deadline to address any technical issues

Plan for Annual Updates:

• Establish processes for updating reports with product changes

• Monitor new products introduced into Kentucky markets

• Track PFAS formulation changes requiring report amendments

☑ Monitor PFAS Working Group Developments

Track Policy Evolution:

• Follow PFAS Working Group meetings and recommendations

• Assess potential future restrictions or phase-out requirements

• Participate in industry comment processes on proposed regulations

• Engage trade associations advocating for reasonable compliance timelines

Organizations implementing continuous regulatory monitoring stay ahead of Kentucky PFAS policy developments and adapt strategies proactively.

☑ Expand Multi-State PFAS Compliance Readiness

Assess Other State Requirements:

• Evaluate PFAS compliance obligations in California, Maine, Minnesota, Massachusetts

• Identify commonalities in reporting data requirements across states

• Build scalable infrastructure supporting multi-jurisdictional compliance

Leverage Kentucky Compliance Investments:

• Product-level PFAS data compiled for Kentucky supports other state requirements

• Supplier declaration programs benefit all PFAS compliance initiatives

• Testing results and formulation knowledge apply across regulations

☑ Train Cross-Functional Teams

Educate Stakeholders:

• Brief product development teams on PFAS compliance implications for new products

• Train procurement staff on supplier PFAS verification requirements

• Inform sales and customer service teams on Kentucky compliance status

• Update executive leadership on compliance risks and strategic implications

8. How Certivo Simplifies Kentucky PFAS Compliance

Certivo provides manufacturers with an AI-powered compliance management platform specifically designed to navigate Kentucky PFAS reporting requirements and broader PFAS regulatory obligations:

Unified Product-Level PFAS Intelligence

Certivo creates comprehensive visibility into PFAS presence across product portfolios:

• Product-level substance tracking linking PFAS data to specific SKUs and UPCs

• Bill of materials integration mapping PFAS through components and materials

• Supplier declaration consolidation organizing PFAS certifications by product

• Testing results management linking laboratory data to product records

Organizations achieve the product-level PFAS intelligence required for accurate Kentucky reporting without manual data compilation from disconnected sources.

Automated Kentucky Reporting Preparation

Certivo streamlines Kentucky PFAS compliance workflows:

• Automated data compilation assembling required reporting elements from centralized databases

• Quality control validation flagging incomplete data or inconsistencies before submission

• Report generation creating Kentucky-compliant submissions from product data

• Annual update workflows managing ongoing reporting obligations efficiently

The platform eliminates manual report preparation that consumes weeks of compliance team time and introduces data accuracy risks.

Intelligent Supplier Declaration Management

Certivo automates supplier PFAS verification:

• Standardized declaration templates aligned with Kentucky reporting requirements

• Automated supplier engagement distributing requests and tracking responses

• Validation rules ensuring supplier data includes required elements

• Non-response escalation automatically following up with suppliers

Organizations scale supplier compliance verification across hundreds of suppliers without manual tracking creating bottlenecks.

Multi-State PFAS Compliance Visibility

Certivo provides unified visibility across Kentucky and other state PFAS requirements:

• Jurisdiction-specific tracking showing compliance status by state

• Cross-state data reuse leveraging Kentucky PFAS data for other state reports

• Comparative analysis identifying products subject to multiple state requirements

• Expansion readiness supporting rapid response to new state PFAS regulations

Organizations investing in Kentucky PFAS compliance build infrastructure supporting multi-state regulatory readiness rather than isolated state-by-state efforts.

AI-Powered Regulatory Intelligence

Certivo's AI continuously monitors Kentucky PFAS regulatory developments:

• Working Group tracking monitoring PFAS Working Group activities and recommendations

• Regulatory update alerts notifying teams of Kentucky policy changes

• Impact assessment identifying products affected by new requirements

• Deadline management ensuring timely compliance with reporting obligations

The platform eliminates manual regulatory monitoring that creates gaps between policy changes and organizational awareness.

Audit-Ready Documentation

Certivo organizes compliance evidence supporting Kentucky PFAS reports:

• Supplier certification repositories maintaining current PFAS declarations

• Testing records management linking laboratory reports to products

• Data lineage tracking documenting basis for reported PFAS data

• Compliance history demonstrating due diligence over time

Organizations respond confidently to Kentucky EEC inquiries with complete, organized documentation rather than scrambling to assemble evidence after the fact.

Cross-Functional Collaboration

Certivo connects teams across compliance, product development, procurement, and operations:

• Role-based access providing relevant Kentucky PFAS data to each stakeholder

• Workflow automation routing compliance tasks appropriately

• Notification systems alerting teams to actions requiring attention

• Executive dashboards giving leadership visibility into Kentucky compliance readiness

The platform transforms Kentucky PFAS compliance from siloed activities to coordinated, enterprise-wide capabilities.

Conclusion

Kentucky PFAS compliance under HB 196 creates mandatory reporting obligations effective January 1, 2027 for manufacturers whose products contain intentionally added PFAS. The regulation extends across multiple industries—from electronics and automotive to textiles, cosmetics, and consumer goods—requiring product-level PFAS disclosure that most organizations cannot compile from existing data systems.

Organizations approaching the January 1, 2027 deadline face compressed timelines for product portfolio assessment, supplier data collection, testing validation, and report preparation. Those starting compliance activities in Q3 or Q4 2026 will struggle to meet the deadline without automated compliance infrastructure accelerating data compilation and validation.

Beyond immediate Kentucky reporting, HB 196 compliance preparation builds capabilities supporting broader PFAS regulatory obligations across multiple states. Product-level PFAS intelligence, supplier declaration programs, and substance tracking infrastructure developed for Kentucky reporting enable scalable compliance as additional states implement independent PFAS requirements.

The question is not whether your organization will achieve Kentucky PFAS compliance by January 1, 2027. The question is whether you will build the compliance infrastructure required to maintain ongoing annual reporting obligations while adapting to expanding multi-state PFAS regulatory frameworks.

Ready to transform your Kentucky PFAS compliance approach? Contact Certivo to see how AI-powered compliance automation helps organizations meet the January 1, 2027 reporting deadline while building scalable infrastructure for multi-state PFAS regulatory readiness.