USA: Minnesota amends lead, cadmium and PFAS bans
July 2025 - Electrical and electronics, hardlines, softlines, toys and children's products
The US State of Minnesota published amendments to legislation for products containing lead, cadmium, and perfluoroalkyl and polyfluoroalkyl substances (PFAS) in June 2025.
During the 2024 legislative session, the Minnesota State Legislature required the Minnesota Pollution Control Agency (MPCA) to develop and submit policy recommendations1 concerning the use of the above substances in consumer products. This initiative aims to guide future regulatory decisions and evaluate whether the restrictions on these substances should be modified.
Bill HF42 amends Minnesota Statutes 2024, section 325E.3892 regarding the scope and exemptions of lead and cadmium restrictions. This update is effective 15 June 2025. Table A lists the details of requirements.
Meanwhile, Bill SF33 modifies the PFAS legislation, which includes a ban, effective 1 January 2025, on the sale or distribution within Minnesota of products with intentionally added PFAS in 11 product categories. All remaining products with intentionally added PFAS will be banned within Minnesota by 1 January 2032, unless the PFAS in these later products is a currently unavoidable use. The latest amendment would exempt the electronic components or internal components in the 11 product categories.
Besides, the amendment also includes new exemptions for specific children's products including off-highway vehicles, all-terrain vehicles, off-highway motorcycles, snowmobiles, electric-assisted bicycles and the replacement parts for the above vehicles. In addition, this update also adopts a deadline of 1 January 2028 for class B firefighting foam for use in fixed firefighting systems in a hangar at an airport and an extension one-year may be allowed if necessary.
Table A: Minnesota's lead and cadmium ban
Parameter | Details |
|---|---|
Covered products | (1) jewelry; (2) toys; (3) cosmetics and personal care products; (4) puzzles, board games, card games, and similar games; (5) play sets and play structures; (6) outdoor games; (7) school supplies, except ink pens and mechanical pencils; (8) pots and pans; (9) cups, bowls, and other food containers; (10) craft supplies and jewelry-making supplies; (11) chalk, crayons, children's paints, and other art supplies except professional artist materials, including but not limited to oil-based paints, water-based paints, paints, pastels, pigments, ceramic glazes, markers, and encaustics; (12) fidget spinners; (13) costumes, costume accessories, and children's and seasonal party supplies; (14) keys, key chains, and key rings; and (15) clothing, footwear, headwear, and accessories |
Exemption | (1) covered products when regulation is preempted by federal law; (2) covered products with lead in solder used in internal components if: i) not imported, manufactured, sold, held for sale, distributed, or offered for use in the state after 1 July 2028 and ii) the Manufacturer submits biennial reports to the MPCA explaining: Barriers to removing lead, the progress towards lead-free alternatives and the timeline for fully adopting lead-free alternatives; (3) keys with lead, imported, manufactured, sold, held for sale, distributed, or offered for use in Minnesota before 1 July 2028; (4) keys with lead ≤ 1.5% by total weight, imported, manufactured, sold, held for sale, distributed, or offered for use in Minnesota after 1July 2028; (5) pots and pans if: i) made of cast iron or steel; ii) cadmium is contained only in a vitreous enamel that does not contact with food; and iii) does not contain lead in concentration greater than the limit of 90 ppm. |
Limit values | Total lead content ≤ 90 ppm or total cadmium content ≤ 75 ppm. |
Table B: Summary of PFAS ban in Minnesota
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. |
On or before 1 January 2026 | Any products | The manufacturer of products containing intentionally added PFAS shall notify MPCA commissioner with below information:
|
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:
[2] Minnesota Session Laws – 2025, 1st special Session, HF4 – Lead and cadmium restriction
[3] Minnesota Session Laws – 2025, 1st special Session, SF3 – PFAS modification
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