The RV Industry Association (RVIA) testified before the New Mexico Environmental Improvement Board on February 23, opposing a proposed rule that would require PFAS labeling for recreational vehicles sold in the state.
The rule is part of implementing the New Mexico PFAS Protection Act, which was signed into law on April 8, 2025, to phase out consumer products containing intentionally added PFAS.
Under the law, manufacturers of non-exempt products must report detailed PFAS content beginning in 2027.
The legislation includes exemptions for certain categories, such as motor vehicles, including motorized and towable RVs, which the legislature determined pose minimal consumer risk.
Despite these statutory exemptions, the New Mexico Environment Department’s proposed rule would mandate PFAS labeling for all products, including those already exempt.
RVIA argued that requiring PFAS labeling for RVs would impose an “enormous burden” on manufacturers, who must source thousands of parts from a diverse global supply chain.
Under the proposed labeling provisions, manufacturers would need to collect PFAS information for hundreds of components and list them in owner’s manuals, including their specific location within the RV.
“Requiring PFAS labeling for RVs is unnecessary, overly burdensome to RV manufacturers, and could cause confusion to consumers,” the association said in a News and Insights report of RVIA.
The association urged the board to align the rule with legislative intent by excluding RVs from labeling requirements.
The Environmental Improvement Board began a multi-day public hearing to review the proposed rule, with a final determination expected by March 6.
If adopted as currently drafted, RV manufacturers would need to comply with labeling requirements starting with the 2027 model year.
In addition to testimony, RVIA is submitting written comments to advocate for a final rule that reflects statutory exemptions and minimizes regulatory burdens on manufacturers.
The organization emphasized the importance of distinguishing complex durable goods like RVs from smaller consumer products in the regulatory framework.