Who must report
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 2026-07-29. 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 three dates
| Date | What happens | Fee |
|---|---|---|
| Aug 16, 2026 | Extension requests must be postmarked. A granted request buys a one-time 90-day extension, to December 14, 2026. Waiver requests are due on the same postmark date. Whether a waiver could even apply to you is a counsel question, not a form question. | $300 per extension request, paid by paper check per MPCA’s instructions; $800 per waiver request. |
| Sep 15, 2026 | Initial PFAS in products reports are due to MPCA. The agency has publicly reaffirmed the date and has signaled no further blanket extension. | $800 one-time initial reporting fee per manufacturer. |
| Dec 14, 2026 | Extended deadline, where an extension was granted. This is all the August 16 postmark buys: thirteen more weeks of supplier chasing. There is no second 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 (extension and waiver request instructions) — retrieved 2026-07-29. Deadline reaffirmation: MPCA news announcement, June 15, 2026 — retrieved 2026-07-29.
What a defensible extension request contains
An extension request is a document you may one day have to stand behind, so treat it like one. The requests that read as credible — to an agency, and later to anyone auditing your file — contain three things:
- A specific reason. Not “we need more time” but which data, for which product families, is not yet obtainable, and why.
- A supplier outreach record. Who you asked, when you asked, what you asked for, what came back, and what is still open — dated. This is the difference between a request and an assertion.
- A completion plan. What you will do with the 90 days: which suppliers get re-chased, which unknowns get escalated, and when the report lands.
Whether MPCA grants any particular request is the agency’s call. We build the readiness pack; we do not predict outcomes, and we never touch PRISM — you file.
The three-part structure is our practice recommendation, not an MPCA requirement; the form and fee mechanics are MPCA’s (link above, retrieved 2026-07-29).
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 between now and September is a supplier evidence chase with a dated record — and why starting it in August 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 the extension readiness pack — with every determination recorded as yours, not ours. It is private and by conversation only.