California AB 1200, the Safer Food Packaging and Cookware Act, bans regulated PFAS in plant-based food packaging and requires cookware manufacturers to disclose hazardous chemicals to consumers. Signed in October 2021, its packaging ban took effect January 1, 2023, and its cookware label requirements followed on January 1, 2024.
The law splits into two very different regimes. Food packaging faces an outright chemical ban. Cookware faces a disclosure regime, not a ban, covering PFAS and other substances on the Department of Toxic Substances Control’s Candidate Chemical List, which includes chemicals such as BPA.
The PFAS Ban on Plant-Based Food Packaging
Since January 1, 2023, no person may distribute, sell, or offer for sale in California any plant-based food packaging that contains regulated PFAS. Plant-based packaging means items made primarily from paper, paperboard, or other plant-fiber materials: take-out containers, wrappers, straws, disposable plates, bowls, trays, food boxes, and similar single-use products.
“Regulated PFAS” has two definitions under the law. The first covers PFAS a manufacturer intentionally added to serve a functional purpose. The second covers PFAS present at 100 parts per million or higher, measured as total organic fluorine. That second threshold captures contamination a manufacturer might otherwise claim was unintentional.
A reformulation clause backs up the ban. Manufacturers changing their packaging to comply must use the least toxic alternative available, so swapping one harmful chemical for another does not count as compliance.
Cookware Disclosure Requirements
The cookware side covers pots, pans, skillets, grills, baking sheets, baking molds, trays, bowls, and cooking utensils. Disclosure applies to chemicals present in the handle or in any surface that touches food or beverages during use. The requirements phase in over two years.
Website Disclosure Since January 1, 2023
Cookware manufacturers selling in California must post, on the product’s website, a list of all chemicals in the cookware that appear on DTSC’s designated list, the names of the authoritative lists DTSC referenced when compiling that designated list, and links to those authoritative lists.
Product Label Disclosure Since January 1, 2024
The same chemical information now has to appear on the physical product label. The label must carry the phrase “This product contains:” followed by the list of intentionally added chemicals from the designated list found in food-contact surfaces or handles. It must also include a statement, in both English and Spanish, directing consumers to more information, along with a website address and a QR code linking to the full online disclosure.
Limits on “Free Of” Marketing Claims
AB 1200 also targets misleading labeling. A cookware manufacturer cannot claim a product is “free of” a specific chemical if that chemical belongs to a chemical group or class on the designated list, unless no individual chemical from that group was intentionally added to the cookware. The rule took effect January 1, 2023, for manufacturer websites and January 1, 2024, for product packaging.
In practice, a company cannot label a pan “PFAS-free” if the pan contains any PFAS compound from the designated list. PFAS is a class of thousands of chemicals, and marketing a product as free of one specific compound while using another from the same family is exactly what this provision forbids.
Who Has to Comply
The food packaging ban reaches “any person” who distributes, sells, or offers non-compliant packaging for sale in California. That is broad enough to cover retailers, restaurants, and distributors, not only the companies that made the packaging. A restaurant using take-out containers with regulated PFAS is potentially liable even if it played no role in producing them.
Cookware works slightly differently. The law bars cookware from being sold or distributed in the state unless both the cookware and the manufacturer meet the disclosure requirements. Retailers, then, need to verify that the brands they carry have met the labeling and website obligations, because selling cookware from a non-compliant manufacturer creates enforcement exposure for the retailer.
Manufacturers carry the heaviest load. They must handle the labeling and chemical disclosure, and they must maintain records sufficient to demonstrate compliance, available for inspection.
Penalties and Enforcement
Both the Department of Toxic Substances Control and the California Attorney General can enforce AB 1200. Penalties under the Health and Safety Code run up to $5,000 for a first violation and up to $10,000 for each subsequent violation, and they can be assessed per violation or per day for continuing violations.
The Attorney General’s enforcement advisory notes that non-compliance can also trigger action under California’s Unfair Competition Law and Business and Professions Code section 17500. Those statutes open the door to civil penalties, restitution, injunctive relief, and criminal liability. Civil penalties under the Business and Professions Code can reach $2,500 per violation. Across a statewide product line, per-violation penalties add up fast.