Beginning January 1, 2027, Washington State’s organohalogen flame retardant (OFR) restriction will also cover certain electric and electronic products with plastic external enclosures manufactured, distributed or sold by larger companies.
Washington is part of a broader regulatory trend. A growing number of states have enacted restrictions on flame retardants in priority consumer products, including upholstered furniture, juvenile products, mattresses, and televisions.
Nearly a decade ago, the U.S. Consumer Product Safety Commission (CPSC) issued guidance addressing organohalogen flame retardants in consumer products but stopped short of adopting a federal ban on this class of chemicals in electronics and other covered products.
Washington’s rule — which includes important exemptions for inaccessible electronic components, such as circuit boards — is nevertheless broad in scope. Manufacturers and importers should carefully assess whether their products, components, and plastic enclosures fall within the regulation’s coverage and whether reporting obligations or future restrictions apply.
Some practical steps companies should consider now:
- Engage product safety, engineering, regulatory, and sourcing teams to evaluate chemical content in covered components and enclosures
- Review supplier certifications, material declarations, and testing protocols for OFRs
- Assess whether an exemption request may be appropriate based on performance, safety, or technical feasibility considerations
- Explore the feasibility of alternative materials or flame retardants for plastic enclosures
- Evaluate state-law compliance obligations as part of broader chemicals management and product stewardship programs
For appliance manufacturers and other consumer product companies, the regulation underscores the growing importance of supply chain transparency and proactive chemicals compliance governance.
PLG’s Consumer Product Safety and Stewardship team advises manufacturers and importers on evolving product safety and chemical regulations, including strategies for navigating pending compliance transitions.
