Minnesota PFAS Law Requirements
What does Minnesota's PFAS law require?
Minnesota's PFAS law (Minn. Stat. § 116.943, "Amara's Law") has three parts. Manufacturers must report products that contain intentionally added PFAS to the Minnesota Pollution Control Agency (MPCA). Eleven product categories have been banned from sale since January 1, 2025. From January 1, 2032, every product with intentionally added PFAS is banned unless MPCA has determined by rule that the use is a "currently unavoidable use" (CUU).
Approach: I checked the Minnesota Department of Health restriction records in the datasets, then read the current 2026 statute on the Minnesota Revisor of Statutes site, the adopted MPCA reporting rule (Minn. R. ch. 7026) and MPCA's February 2026 CUU rule-concepts deck. MPCA's own web pages on the reporting deadline would not load.
Scope and key definitions (Subd. 1)
- PFAS: "a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom."
- Intentionally added: PFAS deliberately added during manufacture where its continued presence is wanted in the final product or a component "to perform a specific function."
- Manufacturer: whoever creates or produces the product, or whose brand name is on it. For imported products, it includes the importer or first domestic distributor if the maker or brand owner has no presence in the United States.
- Product: covers product components and items sold for personal, residential, commercial or industrial use, "including for use in making other products."
1. Reporting (Subd. 2, and Minn. R. 7026)
- Who and what: A manufacturer of a product made after July 1, 2023, that is sold, offered for sale or distributed in Minnesota and contains intentionally added PFAS "must submit" a report. The July 1, 2023 cut-off was added by a 2026 amendment (Laws 2026, ch. 127, art. 14, s. 4); the 2025 version had no manufacture-date limit.
- Content required by the statute:
- a product description with a UPC, SKU or other numeric code;
- the purpose of the PFAS, including in components;
- the amount of each PFAS by CAS number;
- manufacturer and contact details.
- Content required by the rule:
- chemical name and CASRN (or another identifier if there is no CASRN);
- the function of each PFAS;
- NAICS or SIC code;
- an authorized representative and an alternate.
- Concentration reporting: either in fixed ranges or as total organic fluorine. The ranges run from "practical detection limit to <100 ppm" up to "90 to 100 percent," plus "present but the amount or concentration range is unknown." Total organic fluorine is allowed if the amount of each PFAS is not known after due diligence.
- Grouping: similar products or components may be reported together only if their PFAS composition, concentration range and function are the same and they differ only superficially.
- Deadlines:
- The statute and rule both say January 1, 2026.
- MPCA's February 2026 deck refers to a "July 1, 2026, deadline" for existing products.
- I could not open MPCA's reporting page to confirm whether that date moved again (MPCA page).
- New products must be reported "by February 1 the following year."
- Updates: by February 1 each year, if in the previous calendar year a product changed significantly, the manufacturer got new product information, or a new product went on sale. The adopted rule dropped the proposed annual recertification.
- Fees:
- $800 flat fee for the initial report.
- Where several manufacturers report as a group, each one pays the $800.
- $300 for an extension request.
- No fee for updates.
- Fees are adjusted for inflation from July 1, 2027.
- Waivers and extensions:
- A waiver is granted where substantially equivalent information is already publicly available.
- Waiver and extension requests are due at least 30 days before the report due date.
- The extension is one 90-day extension of the initial report deadline only.
- Agricultural products reported to the Minnesota Department of Agriculture meet the requirement that way.
- Supply chain and records:
- Every manufacturer is responsible for reporting unless there is a documented reporting agreement.
- Manufacturers must ask their suppliers for the required information until all of it is known.
- Records must be kept for at least 5 years after the PFAS products leave the supply chain.
- Chemical identity can be claimed as a trade secret, but a public chemical subclass must then be given.
- Failure to report: penalties apply under § 116.072. A seller "may not" sell a product whose manufacturer hasn't reported once the seller has been notified.
2. Bans in force since January 1, 2025 (Subd. 5(a))
These 11 categories cannot be sold, offered for sale or distributed for sale if they contain intentionally added PFAS:
- carpets or rugs
- cleaning products
- cookware
- cosmetics
- dental floss
- fabric treatments
- juvenile products
- menstruation products
- textile furnishings
- ski wax
- upholstered furniture
- The Minnesota Department of Health record for cosmetics lists the same January 1, 2025 effective date [1].
- Carve-out: PFAS only in electronic components or internal components is not covered. Internal components include battery holders.
- Juvenile products exclude children's electronics, adult mattresses, and children's off-highway vehicles, ATVs, off-highway motorcycles, snowmobiles and e-bikes, plus their replacement parts.
- MPCA may add more categories by rule, effective between January 1, 2025 and January 1, 2032.
3. Ban on all products from January 1, 2032 (Subd. 5(d))
- All products with intentionally added PFAS are banned unless MPCA rules the use a CUU. A CUU is a use that is "essential for health, safety, or the functioning of society and for which alternatives are not reasonably available."
- The 11 categories above can never get a CUU.
- The CUU rule is still being drafted. MPCA's February 26, 2026 concepts are marked draft and subject to change:
- requests for existing products would be due January 1, 2030;
- each request would need an assessment of alternatives;
- each would go through 30-day public comment and 30-day rebuttal periods;
- first approvals for existing products would last 8 years, approvals for new products 5 years;
- there would be no sell-through after January 1, 2032 without an approval.
- MPCA puts formal proposal in 2027 and adoption at "Date TBD."
- Actions under Subd. 5(c) or (d) on pesticides, fertilizers and soil amendments need the agriculture commissioner's approval.
Testing, notices and enforcement (Subds. 4 and 7)
- MPCA may require test results within 30 days.
- If no PFAS is intentionally added, the manufacturer "must provide" a certificate saying so.
- Manufacturers "must notify" sellers of banned products and give MPCA a list of who they notified.
- Enforcement is under §§ 115.071 and 116.072.
Exemptions (Subd. 8)
- The whole section does not apply to:
- products where federal law preempts state authority on PFAS;
- products regulated under §§ 325F.072 or 325F.075;
- sales or resales of used products.
- The testing and ban provisions do not apply to:
- prosthetic and orthotic devices;
- medical devices and drugs;
- other products used in medical settings or applications regulated by the FDA.
- These products are still subject to reporting.
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Which products are banned?
Since January 1, 2025, Minnesota has banned the sale, offer for sale or distribution for sale of 11 product categories that contain intentionally added PFAS. From January 1, 2032, the ban covers every product with intentionally added PFAS unless MPCA has ruled the use a "currently unavoidable use" (CUU).
Approach: I searched the Minnesota Department of Health restriction records, which hold only the cosmetics entry. I took the full list from the 2026 text of Minn. Stat. § 116.943 on the Minnesota Revisor of Statutes site.
Banned since January 1, 2025 (Subd. 5(a))
| # | Category | How the statute defines it (Subd. 1) |
|---|---|---|
| 1 | Carpets or rugs | "a fabric marketed or intended for use as a floor covering" |
| 2 | Cleaning products | "a finished product used primarily for domestic, commercial, or institutional cleaning purposes" |
| 3 | Cookware | "durable houseware items used to prepare, dispense, or store food, foodstuffs, or beverages" |
| 4 | Cosmetics | Articles applied to the human body to cleanse or beautify. MDH also lists this ban as effective 2025-01-01 [1] |
| 5 | Dental floss | No definition found on the page I read |
| 6 | Fabric treatments | "a substance applied to fabric to give the fabric one or more characteristics, including but not limited to stain resistance or water resistance" |
| 7 | Juvenile products | "a product designed or marketed for use by infants and children under 12 years of age" (with the exclusions covered in my previous answer) |
| 8 | Menstruation products | No definition found on the page I read |
| 9 | Textile furnishings | "textile goods of a type customarily used in households and businesses" |
| 10 | Ski wax | "a lubricant applied to the bottom of snow runners... to improve their grip or glide properties" |
| 11 | Upholstered furniture | "an article of furniture... that is wholly or partly stuffed or filled with any filling material" |
Limits and later phases
-
Components carve-out (Subd. 5(b)): the 2025 ban "does not prohibit" products whose intentionally added PFAS is only in electronic components or internal components.
-
More categories (Subd. 5(c)): MPCA may add categories by rule, with bans taking effect between January 1, 2025 and January 1, 2032.
-
All products from 2032 (Subd. 5(d)): "a person may not sell, offer for sale, or distribute for sale in this state any product that contains intentionally added PFAS" unless MPCA has determined it is a CUU. The 11 categories above cannot get a CUU.
-
Agriculture (Subd. 5(e)): MPCA cannot act on pesticides or agricultural products without the agriculture commissioner's approval.
-
Exemptions (Subd. 8): The bans do not apply to:
- products where federal law preempts state law;
- products regulated under the cross-referenced sections;
- used products;
- prosthetic and orthotic devices;
- FDA-regulated medical devices and products used in medical settings.
Medical products are still subject to the reporting requirement.
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When must manufacturers report PFAS?
The statute and the adopted rule both say January 1, 2026 is the deadline for the first report. MPCA's own February 2026 materials, however, treat July 1, 2026 as the due date for products already on the Minnesota market. After the first report, timing works like this:
- A product with intentionally added PFAS that goes on sale later must be reported "by February 1 the following year."
- Updates are due every February 1, covering changes in the previous calendar year.
- Waiver and extension requests must reach MPCA at least 30 days before the report is due.
Approach: The only Minnesota PFAS record in the datasets is MDH's cosmetics ban, which has no reporting dates. So I read Minn. Stat. § 116.943 and Minn. R. ch. 7026 on the Minnesota Revisor of Statutes site, plus MPCA's February 26, 2026 rule-concepts deck. MPCA's reporting page and its news release on the due date would not load, so I could not confirm the date currently in effect there.
Initial report
- Statute, Subd. 2: "On or before January 1, 2026, a manufacturer of a product manufactured after July 1, 2023; sold, offered for sale, or distributed in the state; and that contains intentionally added PFAS must submit" the report. The cut-off for products made after July 1, 2023 was added in 2026 (2026 c 127 art 14 s 4).
- Rule, 7026.0030 subp. 1: the report "must" be submitted "on or before January 1, 2026."
- MPCA, February 26, 2026: says information on existing products "will already be reported (July 1, 2026, deadline)" (slide 20). Both the statute and the rule still read January 1, 2026. A July 1, 2026 date therefore comes from MPCA's handling of the deadline, not from the published texts. I could not open the MPCA page that would show the current due date.
Products that come on the market later
- Statute, Subd. 2: a manufacturer "must submit" the information "whenever a new product that contains intentionally added PFAS is sold, offered for sale, or distributed in the state."
- Rule, 7026.0030 subp. 1: a new product with intentionally added PFAS after January 1, 2026 "must" be reported "by February 1 the following year."
Annual updates (Rule 7026.0040)
- An update "must" be submitted "by February 1 each year" if, during the previous calendar year, any of these happened:
- the product changed significantly;
- the manufacturer has new information about the product;
- a new product went on sale in Minnesota.
- Under the statute, MPCA can also ask for an update at any time.
- Missing an annual update can lead to penalties under § 116.072.
Extensions (Rule 7026.0060)
- The request "must" be submitted "at least 30 days before the reporting due date."
- If MPCA finds the extension justified, it "must grant one 90-day extension."
- If the request is denied, the report is due within 30 days of the denial notice or by the original due date, whichever is later.
- The request needs the extension fee (Rule 7026.0100, subp. 5).
Waivers (Rule 7026.0050)
- A waiver is available where "substantially equivalent information is publicly available."
- The request "must" be submitted "at least 30 days before the applicable reporting due date."
- If the waiver is denied, the same timing applies: within 30 days of the denial notice or by the due date, whichever is later.
Related date
For products that will need a currently unavoidable use (CUU) determination to stay on sale after the January 1, 2032 ban, MPCA's draft proposal is that requests for existing products are due January 1, 2030 (slide 34). This is a draft and "subject to change"; MPCA expects to propose the rule formally in 2027.
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