IL SB 2076 (2024)
Illinois SB 2076, signed in 2024 and effective January 1, 2026, establishes the broadest scope of any US PFAS food packaging ban. The law prohibits PFAS not only in all food packaging materials but extends uniquely to coatings, inks, and adhesives used on food packaging. This means that even if the packaging material itself is PFAS-free, a PFAS-containing ink or coating applied to that packaging violates the law. No other US state currently reaches this deep into the packaging manufacturing process.
The Illinois EPA is the designated enforcement agency, with civil penalties up to $5,000 per violation. The extended scope means that compliance requires verification at multiple levels of the supply chain: the base packaging material, any applied coatings for grease resistance or moisture barrier, printing inks used for branding or labeling, and adhesives used in assembly. For food brands that use custom-printed packaging, this creates additional compliance obligations that go beyond simply sourcing PFAS-free containers.
Illinois provides a six-month sell-through period for packaging manufactured before the effective date, giving businesses a limited window to deplete existing inventory. For Chicago's massive food service industry, downstate food manufacturers, and packaged food brands distributed through Illinois, the January 2026 effective date requires advance planning. The coatings and inks requirement in particular may require conversations with printers and label manufacturers that food businesses have not previously needed to have about PFAS.
IL SB 2076 (2024)
All food packaging + coatings, inks, and adjacent items
Prohibits PFAS in all food packaging, and uniquely extends to coatings, inks, and adhesives used on food packaging. One of the most comprehensive scopes in the US.
Civil: up to $5,000 per violation
Civil penalties up to $5,000 per violation. Enforced by Illinois EPA.
Exemptions
Illinois'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.
Verify Packaging, Coatings, Inks, and Adhesives
Illinois uniquely covers coatings, inks, and adhesives on packaging. Contact your packaging printer and coating suppliers to confirm that all applied materials are PFAS-free, not just the base packaging itself.
Audit Custom-Printed Packaging for Ink Compliance
If you use branded or custom-printed food packaging, verify with your printing supplier that the inks used are PFAS-free. This requirement is specific to Illinois and may not be on suppliers' standard compliance checklists.
Plan Around the Sell-Through Period
Packaging manufactured before January 1, 2026 has a six-month sell-through window. Time your inventory orders so you are not left with large quantities of non-compliant stock after the sell-through period expires.
Engage Illinois EPA Early on Compliance
With enforcement beginning in 2026, establish compliance documentation now. Illinois EPA may publish guidance or FAQs before the effective date — monitor their communications for clarifications on the coatings and inks provisions.
Use our free compliance checker to verify your food packaging meets Illinois's PFAS regulations.
Run Free Compliance CheckLegal Disclaimer
This page provides general information about Illinois'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.