Key Points

• Minnesota’s PFAS reporting law now excludes older products. Products manufactured before July 1, 2023, are no longer subject to the state’s PFAS-in-products reporting requirements under Amara’s Law.
• Manufacturers and retailers should focus on newer inventory sold in Minnesota. Products made after the deadline that contain intentionally added PFAS still need to be reported through the MPCA’s PRISM system, with limited exceptions.
• Key PFAS compliance deadlines are approaching. Initial PFAS-in-products reports are due Sept. 15, 2026, and extension requests are due by Aug. 16, 2026.

Minnesota will exclude products manufactured before July 1, 2023, from the state’s PFAS-in-products reporting obligations.

Legislation signed May 28, 2026, by Gov. Tim Walz provided welcome relief to manufacturers — particularly those responsible for legacy replacement parts — and retailers with older inventory still available for sale. But a Sept. 15, 2026, deadline for reporting PFAS in products and an Aug. 16 deadline for requesting an extension are still fast approaching.

This alert explains the program’s background, the scope of the new exclusion and the upcoming deadlines.

What Is Amara’s Law

In May 2023, Minnesota enacted its PFAS pollution prevention law, commonly known as Amara’s Law, establishing one of the nation’s most comprehensive PFAS-in-products reporting regimes: Minn. Stat. §116.943. The overarching goal of the law was to phase out all nonessential uses of per- and polyfluoroalkyl substances (PFAS) in products sold in Minnesota by 2032. PFAS are a broad class of synthetic chemicals prized for their durability and resistance to heat, water and oil, but they have drawn intense regulatory scrutiny because they persist in the environment and can accumulate in the human body.

To carry out these reporting requirements, the Minnesota Pollution Control Agency (MPCA) developed the PFAS Reporting Information System for Manufacturers, known as PRISM. PRISM soft-launched in December 2025, and the MPCA has since released multiple upgrades to improve the user interface and expand the chemical database available to filers. For each product that contains intentionally added PFAS, the report must include, inter alia, a description of the product; the purpose/function that PFAS plays in the product; and the amount and name of each type of PFAS. Reports submitted through PRISM are publicly accessible, except for trade-secret data.

The New Exclusion

The most significant recent development is the enactment of 2026 Minnesota Laws, chapter 127, article 14, section 4, which Governor Walz signed after the most recent legislative session. Under the amended statute, manufacturers or their representatives are still required to report products that are sold, offered for sale, or distributed in Minnesota and contain intentionally added PFAS. But now the reporting requirement only applies to products manufactured after July 1, 2023. Previously, Minnesota’s reporting obligation applied regardless of when a product was manufactured, meaning that decades-old inventory still on shelves technically triggered a filing requirement.

The MPCA explained that this amendment grew out of its direct conversations with product manufacturers, particularly those responsible for replacement parts fabricated years ago that remain available for purchase. Locating PFAS information for these legacy products proved especially difficult because the products were created before Amara’s Law existed and, in many cases, before PFAS disclosure was part of supply-chain documentation practices. By tying the reporting obligation to a date shortly after the passage of Amara’s Law, the Legislature aligned the reporting duty with the statute’s forward-looking purpose: phasing out nonessential PFAS going forward rather than cataloguing historical chemical content that may be impossible to verify.

This change substantially narrows the universe of reportable products. Companies that sell long-lived spare parts, refurbished goods or legacy inventory manufactured before mid-2023 no longer need to investigate and report PFAS content for those items. That said, any product manufactured after July 1, 2023 — even a replacement part designed decades ago but produced on a new run — remains subject to full reporting if it contains intentionally added PFAS and enters the Minnesota market. Businesses should therefore focus their compliance efforts on date-of-manufacture documentation to confirm whether individual SKUs fall within or outside the revised obligation.

Key Deadlines

Initial PFAS-in-products reports are due Sept. 15, 2026. If a manufacturer needs additional time, an extension request along with the associated fee must be postmarked on or before Aug. 16, 2026. Manufacturers that request and receive the available single 90-day extension will then have until December 14, 2026, to submit their reports. The MPCA has an available form to complete when requesting an extension and has noted that extensive documentation is not required. After the initial filing cycle, annual updates are due each Feb. 1 when changes to a manufacturer’s reported information require an update.

Practical Takeaways and Next Steps

The older-product exclusion is a pragmatic and welcome refinement to Minnesota’s PFAS reporting regime, but it does not eliminate the underlying compliance obligation for products manufactured after July 1, 2023. Manufacturers and their representatives should:

• Act now to confirm which products in their Minnesota-facing portfolios were produced after that date.
• Assemble available PFAS data from their supply chains so they are prepared to enter information into PRISM in advance of the Sept. 15 deadline.
• Request an extension by Aug. 16 if they are unable to meet the Sept. 15 deadline.

For more information, please contact Ranelle Leier at 612-607-7247 or rleier@foxrothschild.com, or another member of Fox Rothschild’s Environmental Practice Group.

This information is intended to inform firm clients and friends about legal developments, including the decisions of courts and administrative bodies. Nothing in this alert should be construed as legal advice or a legal opinion. Readers should not act upon the information contained in this alert without seeking the advice of legal counsel. Views expressed are those of the author(s) and not necessarily this law firm or its clients. Prior results do not guarantee a similar outcome.