By Giovanna Komst, Deputy Director, The Center for Baby and Adult Hygiene Products (BAHP)

2025 has been a notably active year for policies related to the absorbent hygiene products (AHP) sector. Federal agencies, including the FDA, have continued evaluating areas such as menstrual product performance and safety, while several states have advanced measures related to ingredient transparency and phased reductions of certain chemicals. These developments reflect an evolving regulatory landscape across the U.S. BAHP and its member companies remain engaged in these discussions at both the federal and state levels, with a focus on supporting consumer well-being and encouraging responsible innovation.

Federal Actions

1. FDA: Bench study on tampon materials and potential metal release

The FDA is expected to share results from its bench study that further examines how tampon materials behave under normal use. This work is intended to build on existing evidence, which continues to support that FDA-cleared tampons are a safe option for menstrual care. The upcoming study will provide additional confirmation and clarity once its testing and peer review are complete.

2. FDA Draft Guidance: Menstrual Products: Performance Testing and Labeling Recommendations

In October 2025, the FDA released a draft guidance document outlining recommended performance testing (absorbency, material integrity, microbiological/TSS risk considerations) and labeling practices for tampons, pads, cups and similar products. The draft also clarifies expectations for premarket submissions when required. 

3. U.S. Department of Commerce: Section 232 Investigation of Imports (PPE, medical consumables, devices)

The Department of Commerce opened a Section 232 national security investigation into imports of PPE, medical consumables and medical devices to assess whether reliance on foreign supply chains threatens national security. 

4. U.S. Department of Justice: RFI on State Laws with Significant Adverse Effects on the National Economy or Interstate Commerce

The DOJ issued a Request for Information seeking input on state laws that impose significant adverse effects on national commerce. The RFI provided the public with an opportunity to document how a patchwork of state rules creates operational burdens and to advocate for harmonization. 

State Actions

Note: Bills vary in status and not all have been passed.

California
5. SB 682: PFAS substances
Creates aggressive PFAS phaseout measures in covered products and applies an “essential use” approach consistent with international trends, restricting PFAS to narrowly defined essential applications.

6. SB 754: Menstrual products, concerning chemicals
Requires manufacturers to maintain data on metals (lead, arsenic, cadmium, zinc) and other chemicals in menstrual products. DTSC may add chemicals to the list, set testing standards and lab accreditation, publish test results and health-impact analyses and require independent testing funded by manufacturers.

Illinois
7. HB 2516: PFAS Product Ban (amendment to PFAS Reduction Act)
Expands PFAS definitions and restrictions; makes it illegal to sell menstrual products with intentionally added PFAS beginning January 1, 2032. Establishes enforcement and civil penalties.

Massachusetts
8. HB 1032: Establishes environmental accountability in the fashion industry
Requires qualifying “fashion sellers” to perform supply-chain environmental due diligence, track chemical and wastewater impacts, set GHG reduction targets and submit publicly available compliance reports.

9. HB 2375: An Act relative to menstrual product ingredient disclosure  
Mandates listing all intentionally added ingredients on packaging in a minimum of 10 point font and requires online, machine-readable ingredient directories. Effective 12 months after passage.

10. SB 1483/ now SB 2641: An Act relative to menstrual product ingredient disclosure
Companion/alternative Senate bill; original language was substantially similar to ingredient-disclosure requirements in HB 2375. Now requires clear, conspicuous labeling and online posting of ingredients for disposable and reusable menstrual products, effective 12 months after passage.

New Jersey
11. AB 2437/ SB 3643: Requires menstrual product ingredients to be listed on package
Requires on-package ingredient lists and online posting for all disposable and reusable menstrual products. Amended versions contain an 18-month compliance window, website posting requirements, confidentiality (CBI) considerations and phased implementation mechanics.

12. AB 4767: Limits regulated PFAS in menstrual products
Defines regulated PFAS (intentionally added or present above 100 ppm) and prohibits the sale of menstrual products containing regulated PFAS. The Department of Environmental Protection would oversee testing and lab approval.

New Mexico
13. HB 212: Per- & Poly-Fluoroalkyl Protection Act
Comprehensive PFAS control: bans sale/distribution of products with intentionally added PFAS; requires manufacturers to disclose PFAS purpose, identity, and quantity to the Department of Environment; mandates testing/certificates of compliance; allows the Environmental Improvement Board to define unavoidable uses and set bilingual labeling and reporting standards. Exemptions for federal regulatory overlap, medical devices/drugs and critical health/safety uses.

New York
14. AB 1502 / SB 1548: Restriction of substances in menstrual products (enacted 2025, awaits Governor’s action)
Amends General Business Law to prohibit intentional addition of restricted substances (lead, mercury, formaldehyde, phthalates, parabens, PFAS) in menstrual products. The Department of Health, with DEC, will set safe thresholds within one year; statute effective 12 months after enactment and subject to five-year review cycles.

Oregon
15. SB 3512: Prohibits sale/distribution of products with intentionally added PFAS
Bans manufacture, sale, or distribution of covered products containing intentionally added PFAS (including menstrual products among other categories). Requires manufacturer certificates of compliance; operative January 1, 2027.

Vermont
16. H. 238 / Act No. 54 (2025): Phaseout of products containing added PFAS
Builds on 2024 Act 131 (which already addressed PFAS in menstrual and other products) and applies a new definition of ‘intentionally added’; PFAS-containing menstrual products are banned effective January 1, 2026.

Conclusion

The evolving mix of state initiatives and increasing federal activity in 2025 is shaping a new regulatory landscape for the AHP industry, with a strong focus on transparency, product safety and supply-chain readiness. BAHP will continue supporting members through coordination, advocating for science-based alignment and assisting with practical compliance needs. For more information or to inquire about membership, please visit bahp.com or contact gia@bahp.com.