Minnesota’s PFAS Reporting Requirements: Do You Need to Report?

Manufacturers across the United States may soon find themselves subject to Minnesota’s PFAS reporting requirements; even if they have no facilities, offices, or direct sales operations in the state.

Under Minnesota’s “Amara’s Law,” manufacturers of products containing intentionally added per- and polyfluoroalkyl substances (PFAS) must report information about those products to the Minnesota Pollution Control Agency (MPCA) if the products are sold, offered for sale, or distributed within Minnesota. The law applies regardless of where the product is manufactured. As a result, companies located anywhere in the country may have reporting obligations if their products ultimately enter the Minnesota market.

What Are PFAS?

By now, you’ve probably heard of PFAS, often referred to as “forever chemicals.” If you’re unfamiliar with PFAS or their growing regulatory requirements, we encourage you to review our previous blogs on PFAS regulations and reporting requirements.

PFAS are a large group of synthetic chemicals that do not readily break down in the environment. These substances have been used for decades in a wide range of applications due to their resistance to heat, water, oil, and stains.

PFAS can be found in products such as:

• Textiles and apparel
• Food packaging
• Non-stick cookware
• Plastics
• Electronics
• Automotive components
• Construction materials
• Cleaning products
• And more

Because of their widespread use, PFAS have become a common environmental contaminant. These chemicals can remain in the environment for extended periods of time and may accumulate in soil, water, wildlife, and humans. While PFAS have been used for generations, regulatory agencies have only recently begun implementing more comprehensive monitoring, reporting, and management requirements as concerns regarding their potential health impacts continue to grow.

Why Manufacturers Outside Minnesota May Still Have Reporting Obligations

Manufacturers of products that are sold or distributed in Minnesota may be required to submit information such as:

• Product description and categories
• The PFAS chemicals contained in the product
• Concentration ranges of PFAS
• The function PFAS serves within the product
• Manufacturer and contact information

The MPCA has also established due diligence requirements that may require manufacturers to gather information from suppliers and other entities within their supply chain. Documentation supporting these efforts should be maintained.

Minnesota recently extended the initial reporting deadline to September 15, 2026. Manufacturers that require additional time may be eligible to request a one-time 90-day extension. Following the initial reporting cycle, updates may be required if product information changes or new PFAS-containing products enter the Minnesota market.

Note: Minnesota’s reporting program is one of the most expansive state-level PFAS reporting requirements currently in effect. As additional states continue to develop PFAS restrictions and reporting programs, manufacturers may find that information gathered for Minnesota reporting can also support future compliance efforts elsewhere.

What You Should Do Now

Many companies are still evaluating whether PFAS are present in their products and supply chains. Gathering the necessary information can be challenging, particularly for manufacturers with complex products, multiple suppliers, or broad distribution networks.

Businesses that make products containing intentionally added PFAS should begin assessing their products, engaging their suppliers, and determining whether their products are sold or distributed in Minnesota. Early preparation can help avoid compliance challenges as reporting deadlines approach.

Note: The term “intentionally added PFAS” refers to PFAS that a manufacturer deliberately introduces during the formulation or production of a product to achieve a specific technical or functional effect.

How Walden Can Help

Walden can assist you with PFAS compliance evaluations, chemical inventory, and environmental reporting. Contact our team of EHS experts at 860-846-4069 to see how we can help you meet your compliance needs.