Monthly Radar — [Brand], March 2027

1. Urgent — act this month

The Washington apparel restriction is now in effect, and your rain jacket line ships to WA retailers. As of January 1 the state treats 50 ppm total fluorine as an enforcement presumption: at or above that level, Ecology presumes PFAS were intentionally added and the burden shifts to you to show otherwise.

What this means for you: your two DWR-finished rain jackets are the exposed SKUs. Fleece, cotton tees and the accessory line are not in scope. Ecology has signalled that first-round enforcement is document-driven — they ask for supplier attestations before they ask for lab results.

Suggested action: send the attached supplier attestation letter template to your shell-fabric mill this week and ask for a signed return by the end of the month. If the mill will not sign, that is your answer about the fabric, and you should pull a lab test before the next PO. We have pre-filled the template with the 50 ppm total-fluorine language Ecology uses.

2. This month — no action needed, for the record

CPSC recalled a competitors toddler jacket over drawcord strangulation under 16 CFR 1120. Your outerwear uses snap closures with no neck or hood drawcords, so nothing in your line is implicated. We are noting it because buyers at two of your accounts will have seen the recall notice and may ask — the one-line answer is that your jackets have no drawcords at any position.

The California 50 ppm textile threshold took effect January 1, dropping from 100 ppm. Your DWR-free certification from the mill on file covers this, and the certificate language references total organic fluorine, which is the right metric for AB 1817. No new paperwork required.

3. Ahead — start now, land later

New York numeric threshold rulemaking: the comment period closes April 12. New York has not yet set a numeric limit for apparel, and the proposal on the table would align with the 50 ppm figure. If you want the outdoor-apparel exemption preserved past 2028, this is the window to say so — a two-paragraph comment from a small brand carries real weight in this docket, and we will draft it for you if you want.

Colorado textile ban, January 2028: this is 21 months out, which sounds far until you count purchase order cycles. Two more buying seasons, and mills quote 6-9 months on reformulated finishes. Start supplier conversations by Q3 this year so you are not choosing between a compliant fabric and an on-time delivery.

Also on the horizon: Connecticuts full ban lands the same day as Colorado, and your CT wholesale accounts represent about 8% of units. Same fabric change solves both.

4. Ask us anything

Reply to this email with any question about the above, or about something you saw elsewhere and want checked. Unlimited, included in your plan, and answered by a human — usually same day.

Reminder: this brief is monitoring and plain-English summary, not legal advice. When something needs a lawyer we will tell you plainly, and we will tell you what to ask them so the hour is cheap.