While the EPA may be taking a step back on PFAS regulation, states are charging ahead. A growing number of states have adopted laws regulating PFAS in recent years, including Minnesota. Minnesota’s law requires manufacturers who sell products in the state to report on intentionally added PFAS. This includes manufacturers who sell their products to Minnesotans online. A recent Greenberg Traurig memo discusses the required reporting:
“Reports must include information for each covered product or product component containing intentionally added PFAS. Required information includes: a description of the product or product category; the PFAS chemicals used in the product or its components; the amount or concentration range of each PFAS; the function or purpose PFAS serves in the product; manufacturer and contact information; and other information required by MPCA rules. The rules allow certain flexibility, including grouping similar products, reporting concentration ranges rather than exact amounts, and permitting a group of manufacturers or authorized representatives to report together.”
The first wave of reports is due on September 15, 2026. Although for the first year of reporting, manufacturers may apply by August 16 for a one-time extension, extending the deadline to December 14, 2026. While the law starts as a reporting framework, it seeks to ban the use of PFAS in most products by 2032. Manufacturers subject to reporting will likely face impacts outside of Minnesota. As PFAS use is disclosed in these reports, information will spread publicly. Minnesota’s law is just one in the growing patchwork of PFAS compliance.
Our members can learn more about PFAS regulation here.
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