HI SB 3103 (2024)
Hawaii enacted SB 3103 in 2024, banning PFAS in specified types of plant fiber-based food packaging effective December 31, 2024. The law covers specific packaging types including plates, clamshells, bowls, food wraps, and bags made from plant fiber materials. Unlike states with broader scope, Hawaii's law targets particular product categories rather than applying a blanket ban across all food packaging or all plant fiber products. The Hawaii Department of Health (DOH) is the enforcement authority.
Penalties under Hawaii's law are set at $2,500 per violation — the lowest penalty ceiling among states with PFAS food packaging bans. While this may seem modest compared to Connecticut's $50,000 criminal penalties or New York's $25,000 repeat offense fines, the per-violation structure means that a business using multiple non-compliant products could accumulate substantial penalties. For Hawaii's food service industry, which is heavily concentrated in tourism-dependent areas like Waikiki, Maui, and the Big Island, packaging compliance is important for both legal and reputational reasons.
Hawaii's island geography creates unique supply chain considerations. Many food businesses rely on mainland distributors who ship packaging to the islands, and these supply chains may be less responsive to state-specific compliance requirements than local distributors. Businesses should verify that their mainland packaging suppliers are aware of and compliant with Hawaii's specific PFAS restrictions, particularly for the named packaging types covered under SB 3103.
HI SB 3103 (2024)
Plant-fiber based packaging only
Prohibits PFAS in specified plant-fiber food packaging types including plates, clamshells, bowls, and food wraps.
Civil: up to $2,500 per violation
Penalties up to $2,500 per violation. Enforced by Hawaii DOH.
Exemptions
Hawaii's PFAS ban primarily targets manufacturer and distributor in the supply chain. While food service operators are not directly liable, you should request PFAS-free documentation from your packaging suppliers to avoid supply chain disruptions.
Check Coverage for Specific Packaging Types
Hawaii's ban covers specified plant fiber products: plates, clamshells, bowls, wraps, and bags. Verify which of your packaging items fall into these categories — not all plant fiber products may be covered.
Confirm Mainland Supplier Awareness
If you source packaging from mainland distributors, explicitly confirm they are aware of Hawaii SB 3103 and can certify their products shipped to Hawaii meet the PFAS-free requirement.
Request DOH-Ready Documentation
Obtain and retain written PFAS-free statements from packaging suppliers. The Hawaii Department of Health enforces the law, and documentation should be readily available if requested.
Review Packaging Not Listed in Statute
While unlisted packaging types are not currently covered, Hawaii may expand the law's scope. Proactively transitioning all plant fiber packaging to PFAS-free alternatives positions your business for future regulatory changes.
Use our free compliance checker to verify your food packaging meets Hawaii's PFAS regulations.
Run Free Compliance CheckLegal Disclaimer
This page provides general information about Hawaii's PFAS food packaging regulations and is not legal advice. Regulations may change; always verify current requirements with the relevant regulatory authority. PFAS Packaging Check is an information tool — consult qualified legal counsel for advice specific to your situation.