Who must report
Whether a specific product must report is the statute’s call — this guide gives you the dates, fees, and mechanics, with primary sources linked and dated so you (and counsel, if you use one) can verify everything against the originals.
In broad strokes: Minnesota’s “PFAS in products” reporting duty (Amara’s Law) reaches manufacturers, as the statute defines that term, of products sold or distributed in Minnesota that contain intentionally added PFAS. Two things are worth knowing before you spend a week on the question:
- The scope narrowed in June 2026. A 2026 amendment (2026 Minn. Laws ch. 127, signed May 28, 2026) excludes products manufactured before July 1, 2023. For many portfolios a meaningful share of the catalogue drops out on a date test alone — the cheapest screening work you will do all summer.
- “Manufacturer” is a statutory term, not an org chart. Brand owners and importers can be inside it. Where you land is a determination for you and your counsel; our software records that determination with its author, date, and basis — it never makes it.
Scope amendment: 2026 Minn. Laws ch. 127 (signed May 28, 2026); cutoff restated on MPCA, Reporting PFAS in products — retrieved 2026-09-01. The amendment is also summarized in several law-firm client alerts we reviewed the same day; read the session law itself before relying on it.
The next dates
The extension-request postmark window has closed. MPCA says it is processing requests in the order received and will send formal determinations by email.
| Date | What happens | Fee |
|---|---|---|
| Sep 15, 2026 | Initial PFAS in products reports are due to MPCA. For a denied extension, the due date is 30 days after the denial notice or September 15, whichever is later. | $800 one-time initial reporting fee per manufacturer. |
| Nov 14, 2026 | Later waiver requests for extension recipients. A manufacturer that received an extension and later decides to request a waiver should postmark the request by this date. | Check the current MPCA form and instructions. |
| Dec 14, 2026 | Approved-extension reports are due. This date applies where MPCA grants the extension. | — |
Note what the fees are not: the $800 filing fee is not the cost of this program. The cost is the evidence-gathering behind the answers, which no fee schedule captures.
Dates, fees, and payment mechanics: MPCA, Reporting PFAS in products (reporting, extension, and waiver instructions) — retrieved 2026-09-01. Earlier deadline announcement: MPCA news announcement, June 15, 2026 — retrieved 2026-07-29.
If your extension determination is pending
Do not treat a request as an approval. Keep the formal MPCA determination with your reporting record and continue the evidence work against the date that applies to the outcome:
- If approved: the initial report is due December 14, 2026.
- If denied: the report is due 30 days after the denial notice or September 15, 2026, whichever is later.
- Either way: keep requesting missing supplier information, document every attempt, and report using the best available information and allowed unknown values by the applicable date.
Whether MPCA grants any particular request is the agency’s call. We build a customer-reviewable report-readiness workpaper; we do not predict outcomes, and we never touch PRISM — you file.
Extension status, outcome-specific deadlines, and due-diligence guidance: MPCA, Reporting PFAS in products — retrieved 2026-09-01.
Why supplier data is the long pole
As of MPCA’s June 15, 2026 announcement, the agency expected more than 5,000 manufacturers to report. Over 700 companies had registered in the state’s PRISM system, and just over 30 had actually submitted. That gap is not procrastination. Whether PFAS was intentionally added is a formulation question, and the answer lives with the people who make your components, coatings, seals, and inks — not in your PLM. Many suppliers answer slowly, partially, or not at all, and your report has to say something defensible anyway.
That is why the work in front of most teams is a supplier evidence chase with a dated record — and why starting it late is the expensive version.
Participation figures: MPCA news announcement, June 15, 2026 — retrieved 2026-07-29. Figures are as of that date and have not been restated by the agency since.
If Minnesota is on your desk
Our Minnesota PFAS desk runs the date test across your catalogue, runs the supplier chase with no-account evidence links, ages the unknowns, and assembles a customer-reviewable report-readiness workpaper — with every determination recorded as yours, not ours. It is private and by conversation only.