Minnesota Finalizes PFAS Product Reporting Rule

A Rule Revised After Administrative Review

The Minnesota Pollution Control Agency (MPCA) reworked portions of the rule after the Office of Administrative Hearings rejected an earlier draft last summer. The agency updated definitions, clarified reporting expectations, corrected inconsistencies with statutory authority, and revised the fee structure before adopting the final version in November.

What Must Be Reported

Manufacturers must submit one report that covers all products or components containing intentionally added PFAS. Required information includes:

• The product category or type
• Numeric product codes such as UPC, SKU, GPC, or HTS
• PFAS chemicals present and their concentration ranges
• The function PFAS provides in the product
• Manufacturer and authorized representative information

These elements reflect the updated rule language and the administrative corrections made during the final review process.

Deadlines, Waivers, and Extensions

Initial reports and fees are now due July 1, 2026, following MPCA’s decision to grant a six-month statewide extension to help companies prepare for the new PRISM reporting system. Annual updates will be due each February 1, reflecting changes in the previous calendar year.

Manufacturers may request:

• One 90-day extension to the initial reporting deadline
• A waiver if substantially equivalent information is already publicly available
• A statutory waiver pathway when product information has already been reported to the Minnesota Department of Agriculture

Fee Structure

The final rule lowers and clarifies fees. Manufacturers will pay:

• An $800 flat fee with the initial report
• $300 for an extension request
• No fee for voluntary updates

The rule also includes inflation adjustments beginning in 2027.

What Companies Should Do Now

With MPCA planning to open its PFAS Reporting Information System for Manufacturers in early 2026, companies should begin reviewing their product portfolios, confirming whether intentionally added PFAS are present, preparing supplier communications, and determining whether waiver or trade secret protections will be needed. The new rule sets a high bar for product transparency and is expected to influence future PFAS oversight across other states.