As part of the PFAS pollution prevention law called Amara’s Law, manufacturers are required to report intentionally added PFAS in products sold in Minnesota and pay a fee. Initial reports are due by September 15, 2026. Subsequent reports are due each year on February 1. All information except trade secrets will be publicly accessible after a review period.
Those responsible for reporting PFAS in products are encouraged to stay connected by signing up for updates through the PFAS reporting GovDelivery list.
PFAS reporting system
PFAS Product Reporting Information System for Manufacturers (PRISM) is used by manufacturers and their representatives to submit PFAS in product reports and pay related fees. PRISM is used by everyone to view PFAS in product data, except trade secrets, after a review period.
Resources for product manufacturers
Reporting requirement
A manufacturer or group of manufacturers of a product sold, offered for sale, or distributed in the state must submit a report that includes information about each product or component that contains intentionally added PFAS. This includes products only sold online. Manufacturers have been able to prepare for PFAS reporting since Amara’s Law was enacted in May 2023. Minn. Stat. § 116.943, subd. 2 requires reporting a description of the product, the purposes/functions that PFAS play in the product, the amount of each type of PFAS, and other information.
Reporting and fees rules
Minnesota rules adopted after a two-year rulemaking process provide added detail and flexibility for manufacturers, including:
- grouping of similar products options
- allowing for a group of manufacturers to report together
- reporting ranges of PFAS concentrations instead of exact amounts
- waiver, extension, and trade secret requests
- setting a one-time flat fee of $800 per manufacturer to cover implementation costs
The Minnesota Pollution Control Agency (MPCA) extended the initial reporting due date to September 15, 2026. The extension gives manufacturers more time to:
- establish agreements with suppliers to report on their behalf as allowed in state rule
- become familiar with the reporting system (PRISM)
- utilize support from the MPCA
Refer to the rulemaking page for an overview of the process leading to these adopted rules.
PFAS Reporting Information System for Manufacturers (PRISM)
PRISM is based on the successful High Priority Chemicals Data System already familiar to many manufacturers.
- PRISM website
- PRISM user guides on creating an account, completing a report, and accessing data
- PRISM supplemental guide for assistance with various reporting scenarios
Reporting PFAS in products through PRISM will satisfy Minnesota’s requirements and may also meet reporting requirements of other states. Reported data that is not a trade secret will be available to the public after the MPCA reviews and publishes the information in PRISM. Report publishing will be an ongoing process as reports are submitted.
How-to videos
A series of short instructional videos for common reporting processes has been started; the videos are based on topics covered in the PRISM user guide and frequently asked questions.
Technical support
If you experience technical issues within the PRISM system, please email prism@theIC2.org for assistance. For questions on how to report or reporting requirements, please email pfasreporting.mpca@state.mn.us.
When the MPCA determines a technical support request received by email would be more easily addressed over live video with screen sharing, the individual requesting support will be invited to virtual “office hours” with MPCA staff.
PFAS in products reporting extension and waiver requests
The MPCA encourages manufacturers requesting extensions to be brief and focused when completing request forms. A successful request does not require extensive supporting documentation. PFAS in product reports for manufacturers receiving extensions will be due by Dec. 14, 2026.
Waiver requests must simply demonstrate that equivalent PFAS in product information is publicly available and verifiable.
Extension and request forms, along with fees, must be postmarked by Aug. 16, 2026.
Upgrades and enhancements
PRISM has been improved in response to manufacturer feedback since the soft launch of the system in December 2025.
PRISM 1.0 (January 2026)
- additional chemicals and chemical functions added
- additions to guide and supplemental guide
- guidance on what to do where there is a missing data for a chemical name or function
- step-by-step instructions on how to enable macros in the downloadable template
PRISM 1.1 (February 2026)
- additional chemicals added
- open field text change for components
- options for unknown data elements
- overlapping text issue fixed
- typographical corrections
- additions to guide and supplemental guide:
- additional guidance
- examples on product grouping
- guidance for packaging on spare and replacement parts
- guidance for products introduced after July 1, 2026
- guidance on foam blowing agents
- typographical corrections
- additions to FAQs found on webpage
- question on fees
PRISM 1.1.1 (March 2026)
- additional chemicals added
- enhancement to prevent the accidental duplication of an existing chemical
PRISM 1.1.2 (March 2026)
- 190 additional chemicals added
PRISM 1.2 (April 2026)
User interface improvements:
- a button to the create report page to directly download the template, and a pop-up box with reminders to enable macros once downloaded and see the reporting guide for additional information
- locked the header columns on the browser-based data entry table
- additional on page warnings about time outs and that the page does not automatically save your work, and similar reminder text to the session expiration warning pop-up box
Reporting PFAS in products and pollution prevention
The risk of PFAS pollution and human exposure begins when the chemicals are made and persists for centuries after a product containing PFAS is disposed of. Cleaning up PFAS pollution is too difficult and expensive to be an effective solution, so preventing contamination by phasing out nonessential use of PFAS in products is the best way to protect human health, the environment, and our economy.
Reporting PFAS use in products is foundational to helping manufacturers develop safer alternatives to PFAS, informing interested consumers, and guiding progress toward ending all nonessential PFAS use in Minnesota by 2032. Many safer alternatives to PFAS already exist.
Timeline
- May 2023 — PFAS in products reporting requirements are signed into law
- 2023-2025 — the PFAS reporting and fees rulemaking process progresses while manufacturers gather information for reporting
- Fall 2025 — rulemaking is finalized
- December 2025 — PFAS Reporting Information System for Manufacturers (PRISM) enters a soft launch for final review
- January 2026 — PRISM 1.0 is available to all manufacturers
- February 2026 — PRISM 1.1 with enhancements is available
- April 2026 — PRISM 1.2 is available, updated support documents and instructional videos, extension request forms, waiver request forms
- Aug. 16, 2026 — requests for reporting extension and waivers are postmarked on or before this date
- Sept. 15, 2026 — initial reports are due
- Dec. 14, 2026 — reports due for manufacturers receiving extensions
- February 1 each year — annual updates are due when required
Frequently asked questions
- Who must report?
Any manufacturer of a product sold, offered for sale, or distributed in Minnesota and contains intentionally added PFAS must report. A manufacturer includes:
- the entity that produces the product
- the entity that contracts production of the product under its brand or label
- the importer of first domestic distributor if the producer/brand owner has no U.S. presence
- Which PFAS chemicals should be reported?
All intentionally added PFAS as defined by Minnesota law should be reported. Minn. Stat. §116.943 defines PFAS as a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom.
The PRISM system includes a chemical selection list to support reporting; however, this list is not exhaustive and may be added to at any time via an email request to PFASreporting.mpca@state.mn.us. For this reason, static lists may not reflect the most current information
- What information do I need to register for a PRISM account?
- To register for a PRISM account, you will need to provide the account holder’s name, job title, telephone number, and email address.
- To register your company’s profile, you will need to provide the company name, NAICS or SIC code, company mailing address, and company physical address if different from mailing address.
- What about products sold by multiple manufacturers or retailers?
Each manufacturer defined under the rule is responsible for reporting. One entity may submit a report on behalf of others if there is a documented agreement and all verification requirements are met.
- When are reports due?
Initial reports are due Sept. 15, 2026. Subsequent reports and updates to previous reports, when required, will be due each year on Feb. 1.
- What are the fees associated with reporting?
Each manufacturer is required to pay a one-time initial reporting fee of $800. The fee is assessed at the company level within the PRISM reporting system, including companies reported on by an authorized representative. The system is designed to ensure that the fee is charged only once per registered company.
- Who pays the fee for the initial report?
The company submitting a report is responsible for paying all applicable reporting fees. When reporting for another company, reimbursement of the reporting fees can be requested from the other company, however that process must occur outside PRISM.
- Do I have to report my product that is leased in the state?
Yes. Products that are leased, rented, or otherwise distributed in the state are considered “distributed in the state” under Minnesota Rule 7026.0010, Subp. 9. If the product contains intentionally added PFAS, it must be reported.
- Are used products required to be reported?
No. Products that have been previously installed, operated, or otherwise utilized by a prior owner are not required to be reported. This exemption does not apply to products returned to a retailer or offered for resale if they were not previously used.
- My product was originally part of the 2025 product prohibitions but is now included in an exemption from that prohibition because the PFAS is added to internal or electronic components. Do I still need to report?
Yes. Products that contain PFAS only in internal and electronic components are no longer subject to the 2025 sales prohibition but are subject to the 2026 PFAS reporting requirement.
- What if I use recycled materials in my product that may contain PFAS contamination?
This product would not be reported because the PFAS would not be considered “intentionally added.”
- When will data be public?
Reports will appear in the public system after the MPCA completes its review and confirms the information is ready for release. You do not need a PRISM account to view the public data.
- I sell pesticides or fertilizers that contain PFAS. Who do I report to?
The registrant of the pesticide product is responsible for reporting. If you are not the registrant and only sell the pesticide product, you are not responsible for reporting intentionally added PFAS in the product.
The registrant will need to report to either the Minnesota Department of Agriculture (MDA), the MPCA, or both agencies, depending on what parts of the product contain intentionally added PFAS.
All intentionally added PFAS in the pesticide formulation (i.e., active and inert ingredients) must be reported annually to the MDA beginning Jan. 1, 2026. More information on reporting to the MDA is available on its webpage: https://www.mda.state.mn.us/environment-sustainability/pfas-reporting.
All intentionally added PFAS in other components of the pesticide product, including packaging, must be reported to the MPCA.
Pesticide-treated seeds and other pesticide-treated articles containing intentionally added PFAS must be reported to the MPCA.
The manufacturer of the fertilizer, specialty fertilizer, soil amendment, plant amendment, or agricultural liming material product is responsible for reporting. If you are not the manufacturer and only sell the product, you are not responsible for reporting intentionally added PFAS in the product.
The manufacturer will need to report to either the MDA, the MPCA, or both agencies, depending on what parts of the product contain intentionally added PFAS.
All intentionally added PFAS in the product formulation (i.e., active and inert ingredients) must be reported annually to the MDA beginning Jan. 1, 2026. More information on reporting to the MDA is available on its webpage: https://www.mda.state.mn.us/environment-sustainability/pfas-reporting.
All intentionally added PFAS in other components of the product, including packaging, must be reported to the MPCA.
- Am I exempt from reporting?
You are exempt if your product falls into any of these categories:
- products where federal law controls PFAS presence and preempts state authority
- products regulated under Minn. Stat. § 325F.072 or 325F.075
- products that have been previously installed, operated, or utilized; this does not apply to products returned to a retailer or offered for resale if they were never used
- PFAS-containing products or components submitted to a federal agency and designated as classified under 18 U.S.C. § 798
- What if my supplier does not respond or cannot provide PFAS information?
Manufacturers are still responsible for reporting. Under Minn. R. 7026.0080, subp. 1, a manufacturer must assume responsibility for reporting unless another manufacturer has confirmed they have fulfilled the reporting requirements.
If a supplier is unresponsive, you must continue to request the required information and report using the best available information.
- What if my information from my supply chain is incomplete?
Report the information you have obtained by the reporting deadline using options allowed in the reporting system. Continue to request information and make updates as required by Minn. R. 7026.0080 and Minn. R. 7026.0040, subp. 1(A)(2) as new information becomes available by February 1 of the following year.
Maintain documentation of these continued efforts to obtain all relevant PFAS information from your supply chain. MPCA staff may review this documentation to evaluate compliance with this rule and ensure due diligence has been met.
Obtaining complete and accurate information from your supply chain is also important for supporting future regulatory processes, including potential currently unavoidable use (CUU) determinations.
- What counts as due diligence?
Under Minn. R. 7026.0080, subp. 2, manufacturers must request detailed disclosure of required information from their supply chain until all required information is known.
This includes:
- initiating outreach early and following up as needed
- using multiple communication methods (e.g., email, phone, supplier systems)
- clearly communicating regulatory requirements and deadlines
- continuing requests over time until information is obtained
- How should I document supplier outreach?
Under Minn. R. 7026.0080, subp. 3:
- manufacturers must maintain documentation of all communications with other manufacturers
- this includes emails, letters, and responses (or lack of response)
- documentation must be provided to the commissioner upon request
Records must be maintained for at least five years after the product is removed from the supply chain.
Documentation may be maintained in electronic formats, such as email systems (e.g., Outlook), spreadsheets (e.g., Excel), or other business tracking software. Manufacturers may also consider maintaining backup copies to ensure records are preserved and accessible.
- What if I still cannot obtain the information?
If information cannot be obtained after due diligence:
- continue requesting the information from your supply chain
- document all outreach efforts
- report using the best available information
- use allowed “unknown” values where appropriate
- Should I stop trying after I submit my report>?
No. Under Minn. R. 7026.0080, subp. 2, manufacturers must continue requesting information until all required information is known.
Additionally:
- updates are required by February 1 if new information becomes available
- ongoing supplier engagement is part of compliance
- Can I delay reporting if I am waiting on suppliers?
No. Manufacturers are expected to:
- submit reports using available information by the deadline, and cc
- continue due diligence efforts after submission
A one-time extension may be requested, but lack of supplier data does not remove the obligation to report.
- What is required to be in compliance with the PFAS in products reporting requirements?
- assume responsibility for reporting unless another party confirms they have reported
- continuously request information from the supply chain until complete
- maintain detailed documentation of all communications
- retain records for at least five years after the product leaves the supply chain
- report using best available information, including “unknown” values where necessary
- update reports annually (by February 1) as new information becomes available
- Will extensions or waivers be granted automatically?
No. Requests are reviewed by the commissioner, and approval is not guaranteed.
- What reasons justify an extension?
Extensions may be appropriate where additional time is needed to:
- complete supplier outreach and data collection
- resolve data gaps or validation issues
- finalize internal review and reporting processes
Manufacturers should continue to demonstrate due diligence under Minn. R. 7026.0080.
- Do extensions or waivers change annual update requirements?
No.
Extensions: An extension only applies to the initial reporting deadline. Manufacturers are still required to submit annual updates by February 1 of the following year if:
- new information becomes available
- a product changes
- a new product is introduced
Waivers: If a waiver is granted, specific reporting requirements may be waived as determined by the commissioner.
However:
- manufacturers must still comply with any conditions of the Rule
- ensure that required information remains accessible or updated as specified (e.g., through alternative means such as a manufacturer website or other approved format)