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USA: Minnesota adopted PFAS reporting rules

December 2025 - Electrical and electronics, hardlines, softlines, toys and children's products

On 8 December 2025, the Minnesota Pollution Control Agency (MPCA) adopted rules¹ under Amara's Law² requiring manufacturers to report products containing intentionally added per- and polyfluoroalkyl substances (PFAS). These rules aim to increase transparency and reduce PFAS pollution, often referred to as "forever chemicals" due to their persistence in the environment. To allow sufficient time for industries, MPCA extends the first report due³ by 1 July 2026. Subsequent reports are due each year on 1 February.

Passed in 2023, Amara's Law imposes obligations on manufacturers, importers, and distributors. While bans on certain product categories (such as carpets, cleaning products, and cookware) took effect on 1 January 2025. Table A shows the corresponding effective dates of the requirements. After a 2-year rulemaking process, the MPCA implements rules with more details and flexibility for manufacturers including:

Option to group similar products: Manufacturers may consolidate reporting for products that share similar characteristics (such as the same PFAS chemical composition, same reporting concentration ranges) or PFAS usage;
Joint submission by multiple manufacturers: The rule allows a group of manufacturers to submit a combined report, reducing duplication and administrative burden;
PFAS concentration ranges: Instead of providing exact concentrations, manufacturers can report PFAS levels within specified ranges. The total organic fluorine (TOF) content can be accepted if the amount of each PFAS is not known within applicable due diligence standards;
Requests for waivers, extensions, and trade secret protection: Manufacturers may apply for exemptions, deadline extensions, or confidentiality for proprietary information;
One-time flat fee of $800 per manufacturer.

To facilitate these submissions, the MPCA is launching the PFAS Reporting and Information System for Manufacturers (PRISM). Based on the established High Priority Chemicals Data System (HPCDS), PRISM is designed to be user-friendly and secure.

Soft Launch: A pilot version will be available to selected manufacturers in December 2025.
Full Launch: The system will open to all manufacturers in January 2026.

Table A: Timelines of Minnesota PFAS rules

Effective date	Product scope	Requirement
1 January 2025	(1) carpets or rugs; (2) cleaning products; (3) cookware; (4) cosmetics; (5) dental floss; (6) fabric treatments; (7) juvenile products; (8) menstruation products; (9) textile furnishings; (10) ski wax; or (11) upholstered furniture	Prohibited if intentionally added PFAS. Note: electronic components or other internal components are exempted.
1 July 2026 Note: Manufacturers are required to submit annual updates by 1 February each year if there is a significant change made to the products.	Any products	The manufacturer of products containing intentionally added PFAS shall notify MPCA commissioner with below information: product description; PFAS chemicals used in the product or its components; the concentration of PFAS chemicals in the product or its components; the function that each PFAS chemical provides to the product or its components; manufacturers' information; information for the authorised representative of the manufacturers (if any).
1 January 2032	Any products	Prohibited if intentionally added PFAS, unless the PCA commissioner has determined by rule that the use of PFAS in the product is a currently unavoidable use.

Effective date

Product scope

Requirement

1 January 2025

(1) carpets or rugs;
(2) cleaning products;
(3) cookware;
(4) cosmetics;
(5) dental floss;
(6) fabric treatments;
(7) juvenile products;
(8) menstruation products;
(9) textile furnishings;
(10) ski wax; or
(11) upholstered furniture

Prohibited if intentionally added PFAS.

Note: electronic components or other internal components are exempted.

1 July 2026

Note: Manufacturers are required to submit annual updates by 1 February each year if there is a significant change made to the products.

Any products

The manufacturer of products containing intentionally added PFAS shall notify MPCA commissioner with below information:

product description;
PFAS chemicals used in the product or its components;
the concentration of PFAS chemicals in the product or its components;
the function that each PFAS chemical provides to the product or its components;
manufacturers' information;
information for the authorised representative of the manufacturers (if any).

1 January 2032

Any products

Prohibited if intentionally added PFAS, unless the PCA commissioner has determined by rule that the use of PFAS in the product is a currently unavoidable use.

References:

[1] MPCA adopted reporting rules

[2] TÜV SÜD E-ssentials July 2025

[3] Webpage of MPCA PFAS reporting

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