USA: Minnesota postpones requirements of PFAS, Lead and Cadmium in certain products
SEPTEMBER 2024 - ELECTRICAL AND ELECTRONICS, HARDLINES
US Minnesota has postponed1 the enforcement of rules for per- and polyfluoroalkyl substances (PFAS), lead and cadmium for four groups of specific products from January 2025 to July 2025.
In 2023, we reported2 that Minnesota passed the law to regulate PFAS, lead and cadmium in certain products. The law prohibits 11 categories of products containing intentionally added PFAS including upholstered furniture and restricts two heavy metals in certain consumer products. The requirements were set to take effect on 1 January 2025. However, the Bill HB 3911 amended the law to delay the effective date of four groups of products until 1 July 2025.
Table 1: The four product groups with the updated effective date of 1 July 2025
| Scope | Requirement |
| Pens and mechanical pencils | ≤ 90 ppm lead |
| Internal electronic components of key fobs | ≤ 90 ppm lead; and ≤ 75 ppm cadmium |
| Firefighting foam used in fire suppression systems installed in airport hangers | Prohibits PFAS if intentionally added |
| Electronic or other internal components of upholstered furniture | Prohibits PFAS if intentionally added |
In addition to the above updates, Minnesota’s PFAS rules require manufacturers to submit a notification if their products contain PFAS by 1 January 2026. According to the webinar3 held on 18 July 2024, the Minnesota Pollution Control Agency (MPCA) is developing the reporting system, which will be adapting the High Priority Chemicals Data System (HPCDS)4 model that is part of the Interstate Chemicals Clearinghouse5. They are optimistic that the beta version will be ready for testing in the fall of 2025.
[1] Minnesota Bill HF No. 3911
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