Virginia Poised to Join States Requiring Ingredient Disclosure for Menstrual Products

Richmond, VA, US, March 2026 — Virginia is poised to join a growing number of U.S. states requiring greater transparency in menstrual health products after lawmakers approved legislation mandating ingredient disclosure for menstrual supplies sold in the Commonwealth.

The measure, House Bill 998 (HB998), would require manufacturers of products such as tampons, sanitary pads, menstrual cups, discs, and menstrual underwear to disclose product ingredients on packaging and online. Supporters say the bill aims to give consumers clearer information about substances used in products that come into close contact with the body.

If enacted, the legislation would take effect January 1, 2027, placing new compliance obligations on manufacturers distributing menstrual products within the Commonwealth.

Mandatory Ingredient Disclosure

The legislation would require every package or box of menstrual supplies sold in Virginia to include a label listing all intentionally added ingredients used in the product.

Ingredients must be:

• Listed in descending order of predominance

• Presented in a clear and visible format

• Displayed on the consumer-facing packaging

The bill defines menstrual supplies broadly as products used to capture menstruation or vaginal discharge, including:

• Tampons

• Sanitary pads

• Menstrual cups

• Menstrual discs

• Menstrual underwear

Manufacturers that modify a product’s formulation must update labels within 18 months after the modification.

Online Ingredient Transparency

In addition to labeling requirements, HB998 would require manufacturers to make ingredient information available electronically, typically through a company website.

Manufacturers must ensure that:

• The same ingredient list appearing on the package is accessible online

• Ingredient information is updated when formulations change

These digital disclosure requirements are intended to ensure that consumers can easily access ingredient information even after the product packaging is discarded. Manufacturers may use technologies, including a digital link or QR codes, to direct consumers to the website.

Trade Secret Protections

The bill includes provisions designed to protect confidential business information. Manufacturers may withhold the precise identity of substances that qualify as protected trade secrets, including chemicals listed as confidential under the U.S. Toxic Substances Control Act (TSCA) or protected under federal trade secret law or are generally recognized as safe (GRAS) by the U.S. Food and Drug Administration.

However, when a substance is protected, companies must still disclose the common name of the ingredient.

Enforcement and Penalties

The legislation authorizes civil penalties for companies that fail to comply with the disclosure requirements.

Violations could result in civil penalties of up to $1,000 per violation, with collected funds directed to Virginia’s Breast and Cervical Cancer Prevention and Treatment Fund.

Growing National Trend Towards Regulating Menstrual Products

Virginia’s proposal reflects a broader trend across the United States in which states are increasingly regulating menstrual products and personal care through ingredient transparency laws and chemical safety frameworks.

Several states have adopted laws requiring manufacturers to disclose ingredients used in menstrual products. If the legislation is enacted, Virginia would join California and New Jersey in requiring ingredient disclosure on the labels and online websites. Nevada and New Jersey require ingredient disclosure on the labels.

In addition to ingredient transparency, states have also focused on regulating menstrual products through restricting certain substances in menstrual products

Compliance Implications for Industry

If enacted, HB998 could require manufacturers distributing menstrual products in Virginia to implement new compliance measures, including the following:

• Ingredient inventory and verification

• Packaging updates to include full ingredient lists

• Website disclosure systems for product formulations

• Supply chain documentation for proprietary substances

For companies selling products nationwide, the Virginia legislation may further accelerate the need for harmonized ingredient disclosure strategies across multiple state markets. While many of these requirements will impact manufacturers and importers, suppliers and retailers of menstrual products should also ensure products are compliant with these requirements.

State	Ingredient Labeling Requirement	Chemical Restrictions	Compliance Timeline	Primary Source
Virginia	Ingredient labeling on packaging + electronic disclosure	N/A	1 January 2027 – ingredient labeling	Virginia HB998 (Bill Text)
California	Ingredient labeling on packaging + online disclosure	PFAS (intentionally added PFAS prohibited; PFAS exceeding total organic fluorine threshold prohibited)	1 January 2023 – ingredient labeling 1 January 2025 – chemical restriction (PFAS – intentionally added) 1 January 2027 – chemical restriction (PFAS – total organic fluorine threshold)	California AB2515
New York	Ingredient labeling on packaging	PFAS; lead; mercury; formaldehyde; triclosan; toluene; talc; dibutyl phthalate (DBP); diethylhexyl phthalate (DEHP); butylphenyl methylpropional; isobutylparaben; isopropylparaben; butylparaben; propylparaben	1 March 2020 – ingredient labeling 19 December 2026 – chemical restriction (listed substances)	New York GBL §399-AAAA
Nevada	Ingredient labeling on packaging	N/A	1 January 2025 – ingredient labeling	Nevada AB169
New Jersey	Ingredient labeling on packaging + website disclosure	N/A	12 January 2026 – act effective 12 July 2027 – ingredient labeling	New Jersey A2437
Colorado	N/A	PFAS (intentionally added PFAS prohibited)	1 January 2025 – chemical restriction (PFAS)	Colorado HB22-1345
Minnesota	N/A	PFAS (intentionally added PFAS prohibited in menstrual products)	1 January 2025 – chemical restriction (PFAS) 1 January 2026 – PFAS reporting 1 January 2032 – chemical restriction (PFAS – product ban unless unavoidable use)	Minnesota Stat. §116.943
Maine	N/A	PFAS (intentionally added PFAS subject to reporting and future ban)	Reporting requirement currently suspended pending rulemaking 1 January 2030 – chemical restriction (PFAS – product ban unless unavoidable use)	Maine 38 M.R.S. §1614
Connecticut	N/A	PFAS (intentionally added PFAS prohibited in menstrual products)	1 January 2028 – chemical restriction (PFAS)	Connecticut Public Act 24-134
New Hampshire	N/A	PFAS (intentionally added PFAS prohibited in feminine hygiene products)	1 January 2027 – chemical restriction (PFAS)	New Hampshire RSA 149-M:64
Rhode Island	N/A	PFAS (intentionally added PFAS prohibited in menstrual products)	1 January 2027 – chemical restriction (PFAS)	Rhode Island Gen. Laws §23-18.18-3
Vermont	N/A	PFAS; ortho-phthalates; formaldehyde; methylene glycol; mercury compounds; triclosan; 1,4-dioxane (threshold-based); lead compounds; asbestos; m-phenylenediamine and salts	1 January 2026 – chemical restriction (PFAS; ortho-phthalates; formaldehyde; methylene glycol; mercury compounds; triclosan) 1 January 2026 – chemical restriction (1,4-dioxane ≥10 ppm) 1 January 2027 – chemical restriction (1,4-dioxane ≥2 ppm)	Vermont 9 V.S.A. §2494b