Minnesota PFAS law and its product bans and reporting duties
Minnesota PFAS law bans intentionally added PFAS in eleven product categories from 2025. Reporting is separate, and a wider product ban starts in 2032.
Minnesota's PFAS law, called Amara's Law, bans sales in the state of products with intentionally added PFAS in eleven categories from January 1, 2025. It also requires manufacturer reporting and sets a wider product ban for January 1, 2032, subject to exemptions and MPCA determinations by rule. Minnesota Statutes section 116.943 sets out these separate duties.
A report doesn't override a sale prohibition. Check MPCA's reporting guidance for the current submission schedule. The date printed in the statute is not a safe filing date on its own.
What counts as intentionally added PFAS?
PFAS means a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom, not a closed list of named substances. "Intentionally added" means PFAS deliberately added during manufacture where its continued presence is desired in the finished product, or in a component, to perform a specific function. Detectable contamination alone does not establish that PFAS was intentionally added. Section 116.943, subdivision 1
A product is an item manufactured, assembled, packaged or otherwise prepared for sale to consumers, including its components, when sold or distributed for personal, residential, commercial or industrial use, including use in making other products. Commercial and industrial use means this is not a household-only rule. Section 116.943, subdivision 1
Which products have been banned since 2025?
Since January 1, 2025, a person may not sell, offer for sale or distribute for sale in Minnesota a product with intentionally added PFAS in these categories:
- Carpets or rugs
- Cleaning products
- Cookware
- Cosmetics
- Dental floss
- Fabric treatments
- Juvenile products
- Menstruation products
- Textile furnishings
- Ski wax
- Upholstered furniture
That list is section 116.943, subdivision 5(a). A juvenile product is designed or marketed for infants and children under 12. It excludes children's electronic products, adult mattresses, and specified children's recreational vehicles and their replacement parts. It does not mean every product a child uses.
The initial ban does not apply when intentionally added PFAS is present only in electronic components or internal components. That exception is not a reporting exemption, and it does not take the product out of the rest of the law. Section 116.943, subdivision 5(b)
Cosmetics are already on that list. That is not a grace period. January 1, 2032 does not delay the eleven-category ban. Section 116.943, subdivision 5
MPCA may by rule prohibit more categories or uses before 2032. Any such prohibition must take effect no earlier than January 1, 2025 and no later than January 1, 2032, and the statute says to prioritize categories most likely to contaminate or harm the state's environment and natural resources. Check adopted rules before treating the eleven categories as the only current bans. Section 116.943, subdivision 5(c)
Who is responsible for Minnesota PFAS reporting?
Reporting is wider than the eleven banned categories. The statute covers a product manufactured after July 1, 2023, if it contains intentionally added PFAS and is sold, offered for sale or distributed in Minnesota. Section 116.943, subdivision 2
The manufacturer is the person who creates or produces the product, or whose brand name is on it. For an import, the importer or first domestic distributor is included when the manufacturer, assembler or brand owner has no US presence. Running the factory is not the only test. Section 116.943, subdivision 1(o)
Manufacturers must assume reporting responsibility unless others in the same supply chain agree their respective responsibilities. Reporting for another manufacturer still needs the required notification, a documented agreement and verification. A purchase does not, by itself, end the buyer's duty. Rules 7026.0020 and 7026.0080
Information to prepare
The statute asks for a product description and a UPC, SKU or other numeric code, the purpose of the PFAS including in components, the amount of each PFAS by CAS number, and manufacturer and contact details. The commissioner can request further information needed to implement the section. Section 116.943, subdivision 2
Rule 7026.0030 adds the chemical name, an alternative identifier if no CAS number exists, concentration ranges in homogeneous materials, the PFAS function, a NAICS or SIC code, and authorized and alternate contacts. An unknown amount can be reported as "present but amount or concentration range unknown," or as total organic fluorine in specified cases, only with the rule's due diligence. The rule does not tell every manufacturer to test every product. Rule 7026.0030
Dates, updates and fees
The statute and the codified rule both print January 1, 2026 as the initial reporting date. The statute also lets the commissioner extend a deadline. Those texts do not establish the current submission schedule. Check MPCA's current instructions before you set a filing date. Section 116.943, subdivisions 2 and 3
A manufacturer that wants more time must request it at least 30 days before the due date and show why the extra time is justified. If the commissioner finds the request justified, rule 7026.0060 says the commissioner must grant one 90-day extension. That request is not an agency-wide schedule change. Rule 7026.0060
A new product with intentionally added PFAS introduced after January 1, 2026 must be reported by February 1 of the following year. A February 1 update is also due if the previous calendar year brought a significant product change, new product information or a new product supplied in Minnesota. An unchanged report does not have to be recertified every year. Rules 7026.0030 and 7026.0040
The initial-report fee is $800 for each manufacturer, including each one in a group report and each one covered when another manufacturer reports on its behalf. An extension request is $300 per manufacturer. Paying the fee does not authorize sale of a prohibited product. Rule 7026.0100
What changes under the 2032 ban?
From January 1, 2032, no person may sell, offer for sale or distribute for sale in Minnesota any product containing intentionally added PFAS, unless MPCA has determined by rule that the use is currently unavoidable. Statutory exemptions still apply. Section 116.943, subdivision 5(d)
A currently unavoidable use must be essential for health, safety or the functioning of society, and alternatives must not be reasonably available. Manufacturers cannot award themselves that status. MPCA may not make that determination for a product in the initial eleven categories. Section 116.943, subdivisions 1(j) and 5(d)
Agricultural inputs are not automatically exempt. MPCA may not use the interim category rule or the 2032 prohibition for a pesticide, fertilizer, agricultural liming material, plant amendment or soil amendment unless the agriculture commissioner approves the action. Section 116.943, subdivision 5(e)
Which exemptions apply?
Section 116.943 does not apply where federal law governs PFAS in the product in a way that preempts state authority. A federal rule, by itself, is not preemption. The section also does not apply to a product regulated under section 325F.072 or 325F.075, or to the sale or resale of a used product. Section 116.943, subdivision 8(a)
Section 325F.072 is the separate Class B firefighting-foam law. That separate law still restricts Class B foam. Section 325F.072
A used product has been installed, operated or otherwise used for its intended purpose by at least one owner or operator, or is otherwise not pristine. A returned or resold item that was not used that way before resale is outside the exemption. Rule 7026.0010
If MPCA has reason to believe a product offered for sale contains intentionally added PFAS, it may require testing results within 30 days. If those results show none, the manufacturer must provide a certificate. If they show intentionally added PFAS, the manufacturer must provide the results and the subdivision 2 information. The manufacturer must also notify sellers of a product prohibited under subdivision 2 or 5 and give MPCA that list. Section 116.943, subdivision 4
Prosthetic and orthotic devices, a medical device or drug, and a product otherwise used in a medical setting or in an FDA-regulated medical application are exempt from subdivisions 4 and 5. That removes the testing, certificate, seller-notice and sale-prohibition provisions. It does not remove reporting. Section 116.943, subdivision 8(b)
How to prepare a product review
Use this as a working list, not as a substitute for the statute:
- Identify products and components supplied to Minnesota.
- Ask suppliers which PFAS were deliberately added, and what function they perform.
- Map product codes to chemical identifiers and the concentration data you have.
- Record who reports, including any supply-chain agreement and notice.
- Decide the sale ban separately from the reporting duty.
- Check adopted rules for any category banned ahead of 2032.
The list follows the scope and information requirements in the statute and the reporting rules. RegAffairs AI has a citation-backed answer on Minnesota's PFAS requirements.