Do you owe Minnesota a PFAS report? Three questions, answered honestly.

Short answer: if you sell a product into Minnesota, you're the company responsible for that product, and the product contains PFAS that was added on purpose, the state expects a report — and for companies that received an extension, it's due December 14, 2026. Here's how to work out which side of that line you're on.

What this rule is, in one paragraph

Minnesota's PFAS law — called Amara's Law — requires manufacturers to report products containing intentionally added PFAS that are sold in the state. PFAS are a large family of manufactured chemicals used for things like water resistance, stain resistance, nonstick surfaces, and coatings; "intentionally added" means the chemical was put in the product (or a component of it) on purpose to do a job — not that it showed up as trace contamination. Reports go to the Minnesota Pollution Control Agency (MPCA) through its online system, PRISM, and include the chemical's identity, its function in the product, and a concentration range. The agency expects more than 5,000 companies to report. The first deadline was September 15, 2026; the MPCA granted over 1,000 extensions, and that group's reports are due December 14, 2026. Updates are due every year on February 1.

One honesty note before the questions: this page is a plain-English guide to the MPCA's published rules, not a legal determination about your company. The MPCA's own PFAS-in-products reporting page is the final word, and a borderline case is an attorney question. But most companies aren't borderline — they're just uninformed. The three questions below settle the common cases.

The three questions

1. Is the product sold, offered for sale, or distributed in Minnesota?

Physical store, distributor, your own website, Amazon, Etsy, Shopify — the channel doesn't matter, and "products sold only online" are named explicitly in the rule. If a Minnesota customer can buy it and have it shipped there, that's a Minnesota sale. Products manufactured before July 1, 2023 are excluded, and a few categories are exempt by statute (for example, products where federal law controls the PFAS and preempts the state rule). If nothing you sell reaches Minnesota, stop here — this rule isn't yours.

2. Are you the "manufacturer" for this product?

The law's definition is wider than the everyday one. You're the manufacturer if you make the product, if it's made under your brand or label by someone else, or if you import it and the maker has no U.S. presence. A pure retailer reselling a U.S. brand's products is usually not the reporter — that brand is. One company can also report on behalf of others when there's a documented agreement. If you private-label, white-label, or import under your own name, assume this question is a yes until proven otherwise.

3. Does the product contain intentionally added PFAS — and do you actually know?

This is the question almost nobody can answer from their desk, because the answer lives with whoever made the product or its components. PFAS turns up in coatings, treatments, membranes, molded parts, and electronics — including products where it's only in internal or electronic components (those lost their sales-ban exemption but kept the reporting duty). If a supplier's spec sheet, safety data sheet, or declaration names a fluorinated chemical, that's your answer. If nobody has ever asked the supplier, your honest status is "unknown" — and the rule treats "unknown" as a work item, not an exemption: you're expected to ask, keep asking, and document the asking. Recycled-content contamination, by contrast, is not "intentionally added" and isn't reported.

What your answers mean

No to question 1 or 2

This reporting rule doesn't reach you. Keep a note of why — which question you failed and when you checked — because "we looked at it" is a better file than a blank one. If your situation changes (a Minnesota distributor, a private-label line), the answer changes with it.

Yes, yes, and yes — you have a report to file

Your deadline depends on your extension status: September 15, 2026 (already passed) if you never received an extension, December 14, 2026 if you did. The work is gathering each product's chemical identity, function, and concentration range from your suppliers, entering it in PRISM, and paying the state's one-time $800 per-manufacturer fee there. Registering a PRISM account is free (below). The preparation — the supplier chase and the data assembly — is the part that takes weeks, and it's the part we sell: report prep, $895 flat per report.

Yes, yes, and "we're confident there's no intentionally added PFAS"

Then no report is owed — but make the confidence worth something. If the MPCA asks how you know, "nobody ever mentioned it" is not an answer; written supplier confirmations are. Our due-diligence file ($295 flat) is exactly that: we chase a declaration from each supplier, log every response and non-response, and organize it into a file built for the five-year record-keeping the law expects. It's documentation, not a legal conclusion — if a declaration ever turns out to be wrong, the file proves you asked properly.

Yes, yes, and "we honestly don't know"

You're in the largest group there is, and the clock matters most for you. The due-diligence duty starts now: request the information from every supplier, follow up when they don't answer, and keep records of all of it — the MPCA can ask to see them. If the deadline arrives with answers still missing, the rule's answer is to report with your best available information (the system allows "unknown" values) and keep asking, with updates due the following February 1. A documented chase started today is compliance in progress; silence is not.

Two traps worth knowing about

A silent supplier does not pause your deadline. The rule is explicit that a lack of supplier data doesn't remove the obligation to report — and that you must keep requesting information even after you file, until it's all known. And don't confuse reporting with the sales bans. Minnesota also prohibits selling certain product categories with intentionally added PFAS (a rule in force since 2025, widening toward all nonessential uses by 2032). A product can be legal to sell and still need a report — the internal-components products above are exactly that case. Whether a specific product is banned is a separate question from whether it's reportable.

The dates, all in one place

  • September 15, 2026 — the original deadline for initial reports (already passed).
  • November 14, 2026 — last day for companies with extensions to postmark a waiver request instead.
  • December 14, 2026 — reports due for the 1,000+ companies that received extensions.
  • February 1, every year — annual updates due when products change or new supplier information has arrived.
  • Five years — how long supplier-outreach records must be kept after a product leaves your supply chain.

Register in PRISM yourself — it's free

The state doesn't charge for the account; the only state charge is the one-time $800 manufacturer fee, paid inside the system when you report. To register: go to the MPCA's "Reporting PFAS in products" page (search that phrase on pca.state.mn.us), follow its link to the PRISM reporting system, and create your company account — you'll want your company details and a contact who'll own the login long-term. The MPCA publishes a PRISM support page with guides and videos, and runs a mailing list for reporting updates. Do this part yourself even if you hire us: the account and the legal duty stay with your company, and any preparer who asks you to hand over your password and disappear should worry you. (Working inside PRISM together, at your direction and with you present, is different — that's how we help clients who want it.)

If the answer is "we have to file," here's the help

The filing itself is data entry. The hard part is the weeks before it: getting suppliers — often overseas, often slow — to state in writing what's in your products, proving you asked when they don't, and turning the pile of replies into clean per-product data. That's the service. For $895 flat per report we run the supplier chase with a documented attempt log, build the product-by-product data sheets from supplier documents (never invented numbers — gaps are flagged as gaps), and hand you a submission-ready PRISM packet you review before anything is filed. If you'd rather document a no-PFAS position, the due-diligence file is $295 flat.

See the PFAS reporting service
Or go straight there: email inunghwang@gmail.com with the subject PFAS + your company name.

This page is general information about Minnesota's PFAS-in-products reporting rule, summarized from the Minnesota Pollution Control Agency's published guidance and Minnesota Rules chapter 7026 — not legal advice for your specific company. Deadlines, fees, and procedures can change; the MPCA's reporting page is the final word.