Start with product and component materials. PTFE and other fluorinated materials can trigger the need for an applicability review under Minnesota's broad PFAS definition. Do not treat missing information as “PFAS-free.”
Minnesota's reporting program reaches covered products placed into the Minnesota market, including online sales. Products manufactured before July 1, 2023 are excluded from this reporting requirement.
The reporting definition of manufacturer can include the producer, an entity that contracts for production under its brand or label, and in certain circumstances an importer or first domestic distributor. Document any agreement where another manufacturer is reporting on your behalf.
September 15, 2026: initial reports due. December 14, 2026: initial reports due for manufacturers that received an extension. February 1 each year: updates are due when new information becomes available, a product changes, or a new product is introduced.
MPCA lists a one-time initial reporting fee of $800 per manufacturer, paid through PRISM when the initial report is submitted.
If supplier data is incomplete, Minnesota requires continued due diligence. Request the required information, document outreach, use best available information and allowed unknown values where appropriate, and continue supplier follow-up after filing.
Do not assume a missed deadline eliminates the reporting obligation. Confirm applicability, extension status, what information is available, and the appropriate filing or corrective action with MPCA or qualified counsel as needed.
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