Minnesota PFAS Reporting Deadline Nears as Extension and Waiver Requests Close August 16

Manufacturers selling products containing intentionally added PFAS in Minnesota must prepare for a September 15, 2026, reporting deadline, while requests for a 90-day extension or reporting waiver must be mailed to the Minnesota Pollution Control Agency by August 16, 2026.

St. Paul, Minnesota, US, July 2026Manufacturers subject to Minnesota’s PFAS-in-products reporting requirements are entering a critical compliance period, with two major deadlines approaching in quick succession.

Manufacturers or their representatives seeking a 90-day reporting extension or waiver must ensure that their request is postmarked by August 16, 2026. Companies that do not receive an extension or waiver must submit their PFAS reports through the state’s reporting system by September 15, 2026.

The reporting program is part of Amara’s Law, Minnesota’s PFAS pollution prevention framework, and applies to manufacturers from around the world whose products are sold in Minnesota, including through online sales.

Extension and Waiver Requests Must Be Mailed by August 16

Extension and waiver requests must be submitted by mail using the applicable MPCA form. Each request must include payment by check, as electronic payment is not accepted.

Manufacturers should account for mailing time and ensure that their submissions receive an August 16 postmark.

The MPCA has advised manufacturers seeking a one-time 90-day extension to keep their requests brief and focused. Extensive supporting documentation is not necessary for a successful extension request.

Manufacturers granted an extension will have until December 14, 2026, to submit their PFAS-in-products reports.

A manufacturer may request a waiver where equivalent PFAS-in-product information is already publicly available and verifiable. The request must demonstrate that the public information is equivalent to the information that would otherwise be reported to Minnesota.

Manufacturers that receive an extension but later decide to seek a waiver must postmark the waiver request by November 14, 2026.

September 15 Reporting Deadline Follows Closely

Manufacturers that do not obtain an extension or waiver must submit their reports by September 15, 2026.

The reporting obligations apply to manufacturers from around the world whose products containing intentionally added PFAS are sold in Minnesota, including products sold online.

Required reports must include:

  • A description of the product

  • The name of each type of PFAS

  • The amount of each type of PFAS

  • The purpose or function the PFAS performs in the product

Products currently offered for sale but manufactured before July 2023 do not need to be reported.

The MPCA expects more than 5,000 manufacturers to report. In an earlier agency update, more than 700 companies had registered in the PFAS Reporting Information System for Manufacturers, known as PRISM, and more than 30 had already submitted reports.

Except for protected trade-secret information, reports will become publicly available through PRISM after MPCA review.

Companies Without Intentionally Added PFAS Do Not Need to Report

The MPCA has clarified that a company does not need to report or create a PRISM account when its products do not contain intentionally added PFAS.

“Intentionally added PFAS” refers to PFAS deliberately added during manufacturing where the substance is intended to remain in the finished product or a component to perform a specific function.

Although companies in this position are not required to submit reports, the MPCA encourages them to retain records supporting their determination. These records may include supplier certifications or communications confirming that products or components do not contain intentionally added PFAS.

PRISM 1.3 Adds Capacity Ahead of the Deadline

As manufacturers prepare for the September deadline, the MPCA has released version 1.3 of PRISM on 10 July 2026.

The update expands processing and storage capacity for large files and allows users to immediately view up to 10,000 rows after uploading an Excel template or pasting data into the reporting interface, up from the previous 250-row limit.

PRISM will accept more than 10,000 rows at one time, but users must save, exit, and reopen the report to view rows beyond the initial 10,000.

Other updates include:

  • Clarified deadline language in the “create a report” window

  • Additional PFAS chemical names and functions

  • Dropdown menus for public searches by chemical, company, or product

  • A simplified reporting-year display

  • A new chemical-function reference sheet in the Excel template

The changes will not negatively affect reports already in progress. Older Excel templates may still be uploaded, although users must download the latest template to access the new chemical-function reference sheet.

Implications for industry

The Minnesota Pollution Control Agency (MPCA) is encouraging manufacturers to begin preparing now, particularly where companies still need to collect supplier information, determine whether products contain intentionally added PFAS, or organize large product datasets. Companies should also create processes to reassess their obligations when product formulations, components, or supplier information changes. The most impending and critical decision is deciding promptly whether they report by September 15, request an extension, or seek a waiver. Companies that determine no report is required should retain documentation supporting that conclusion.

From the technical aspect, the MPCA has released nine PRISM training videos addressing basic system functions, use of the Excel template, account management, and specific reporting scenarios. Manufacturers are advised to review the PRISM user guide and supplemental guide before entering data. Technical assistance and virtual screen-sharing support are also available for users experiencing system problems.

N. Nguyen

Nhat Nguyen is a US-licensed attorney with over 13 years of experience in product & regulatory compliance issues in the EU, US, and Asia Pacific. He is a frequent speaker at major industry conferences and has advised multinational companies on global environmental and product issues.

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