December 2025 Update
On December 8, 2025. the Minnesota Pollution Control Agency (MPCA) adopted new rules regarding reporting and fees by manufacturers upon submission of required information about products containing per- and polyfluoroalkyl substances (PFAS). The finalized rule contained some clarifications and wording changes and added the annual reporting due date of February 1 for subsequent years rather than requiring manufactures to submit the report before the product can be sold. The final rule also removed the annual recertification, voluntary updates, and fee requirements for reporting updates.
Manufacturers are required to report intentionally added PFAS in products sold in Minnesota and pay a fee, as part of Amara’s law. The law requires reporting a description of the product, the functions of PFAS in that product, the amount of each type of PFAS in that product, and other information. The initial report is due to the MPCA by July 1, 2026. The subsequent reports are due February 1 of each year.
Report Details
Information required in the report includes:
- a brief description of the product or a description of the category or type of product
- similar products can be grouped together if they are comprised of homogenous materials and meet specified criteria
- PFAS chemicals used in the product or its components
- the concentration of PFAS chemicals in a product or components of a product made up of homogeneous material
- The manufacturer can report this either by the concentration range of the total organic fluorine
- the function that each PFAS chemical provides to the product or its components
- manufacturer information
- contact information for the authorized representative of the manufacturer who has the authority to execute or direct others to execute reporting to the state
- an alternative to the authorized representative
A complete list of required information can be found in Minn. R. ch. 7026.0030.
Rulemaking Background
This rulemaking started in May 2023 when the MPCA Amara’s law prohibiting non-essential Per-and Polyfluoroalkyl Substances (PFAS) use in commercial products sold or distributed in Minnesota. This prohibition does not apply to products that contain intentionally added PFAS only in electronic components or internal components. The first provisions under Amara’s law started on January 1, 2025 and included products that fall under these 11 categories:
- carpets or rugs
- cleaning products
- cookware
- cosmetics
- dental floss
- fabric treatments
- juvenile products
- menstruation products
- textile furnishings
- ski wax
- upholstered furniture
Each of these 11 categories are described in further detail on the MPCA’s 2025 PFAS prohibitions webpage.
The prohibition also applies to packaging used with the products listed above. These categories are in addition to prohibitions that took effect on January 1, 2024 on PFAS in firefighting foam and food packaging. The MPCA will not directly notify manufacturers if their products might be prohibited and it is up to each manufacturer to be aware of the regulations and updates that might be applicable to their products.
Trinity is Available to Help
If your facility is subject to Amara’s law and the related reporting requirements Trinity is available to support. For more information on this topic, please contact Russell Novotny by email or Trinity’s Minneapolis Office at 651.275.9900.
