Minnesota PFAS Regulations: Bans, Reporting, and 2032 Deadline

Minnesota’s PFAS regulations combine three moving parts: outright product bans that took effect January 1, 2025 across eleven consumer categories, a manufacturer reporting requirement with a first deadline of September 15, 2026, and a near-total ban on intentionally added PFAS in products arriving January 1, 2032. Separate, earlier rules already prohibit PFAS in Class B firefighting foam and in food packaging. If you make, distribute, or sell products in Minnesota, the compliance clock is running on all of these at once.

Products Already Banned in 2025

Amara’s Law, codified at Minnesota Statutes § 116.943, prohibits the sale or distribution of any product in eleven categories if it contains intentionally added PFAS.¹ The listed categories are:

Carpets and rugs
Cleaning products
Cookware
Cosmetics
Dental floss
Fabric treatments
Juvenile products (strollers, high chairs, and similar items)
Menstruation products
Textile furnishings
Upholstered furniture
Ski wax

There is no exemption process for these categories. The “currently unavoidable use” waiver that will apply to the broader 2032 ban is not available here, and the statute explicitly forbids applying it to any of the eleven listed product types.² A cookware line with a PFAS-based nonstick coating, a stain-resistant carpet treated with fluorinated chemicals, a ski wax containing PFAS — each is already illegal to sell in Minnesota.

What “Intentionally Added” Covers

The statute defines intentionally added PFAS as chemicals deliberately introduced during manufacturing where their continued presence in the final product performs a specific function.² Trace contamination from manufacturing equipment or environmental exposure falls outside the definition, though the law sets no numeric cutoff for that line.

Location within the product matters, too. Items that contain PFAS only in electronic or internal components, rather than in a surface a consumer touches, are treated as a 2032 issue rather than a 2025 one. Pre-treated fabrics that arrive at a furniture manufacturer already coated with PFAS are also handled under the 2032 rules.¹

Firefighting Foam and Food Packaging

Two product bans predate Amara’s Law and remain in force. Under Minnesota Statutes § 325F.072, no person, government agency, or fire department may manufacture, sell, distribute, or use Class B firefighting foam containing PFAS. This restriction is not limited to intentionally added PFAS; any Class B foam containing these chemicals is covered.³ Airport hangars with fixed firefighting systems have an exemption through January 1, 2028, with possible one-year MPCA extensions. A broader airport exception continues until the FAA issues transition guidance, qualifies a fluorine-free foam, and that foam becomes commercially available in sufficient quantity.

Food packaging is covered separately by Minnesota Statutes § 325F.075, which bars the manufacture and knowing sale of food packages containing intentionally added PFAS. Grease-resistant coatings on fast-food wrappers, microwave popcorn bags, and takeout containers are the typical targets.⁴ Retailers who knowingly stock noncompliant packaging bear the same liability as manufacturers.

Manufacturer Reporting to the MPCA

Any manufacturer selling a product in Minnesota that contains intentionally added PFAS must report to the Minnesota Pollution Control Agency. The statutory obligation begins January 1, 2026, but the MPCA has set the first submission deadline at September 15, 2026, through its online portal called PRISM. Manufacturers who request an extension have until December 14, 2026, and annual updates are then due each February 1.⁵ The MPCA charges a one-time flat fee of $800 per manufacturer.

Each report must include:

A product description and a UPC, SKU, or other numeric identifier
The purpose the PFAS serves in the product or its components
The amount of each PFAS compound present, identified by CAS registry number
The name, address, and phone number of a responsible person at the company

The reporting duty is not limited to products still on sale. It applies to any product with intentionally added PFAS that a manufacturer sells in Minnesota, so companies typically need supply-chain data going back through their component sources. State rules require manufacturers to request PFAS information from upstream suppliers until all required data is known, keep records of those communications for at least five years after the product leaves the supply chain, and produce the records to the MPCA on request.⁵

Manufacturers with federal reporting obligations should be aware that Section 8(a)(7) of the Toxic Substances Control Act imposes a separate PFAS reporting requirement to the EPA. The federal data set is broader than Minnesota’s, and one submission does not satisfy the other.⁶

The 2032 Near-Total Ban

On January 1, 2032, § 116.943 expands to prohibit the sale or distribution of any product containing intentionally added PFAS unless the MPCA has specifically designated that use as “currently unavoidable.”² The statute defines a currently unavoidable use as one the MPCA commissioner determines by rule to be essential for health, safety, or the functioning of society, and for which alternatives are not reasonably available.

The MPCA is developing the rulemaking framework for these determinations, collecting feedback on proposed rule concepts and continuing to draft through 2026 and into 2027.⁷ Manufacturers seeking a designation will need to show that PFAS are technically necessary for the product to function, that no safer alternative is reasonably available, and that the use serves a genuine health, safety, or societal need. Products in the eleven 2025 categories cannot receive this exemption under any circumstances.²

Penalties and How Enforcement Works

The MPCA commissioner enforces Amara’s Law under Minnesota Statutes §§ 115.071 and 116.072, and may coordinate with the commissioners of agriculture, commerce, and health.² Administrative penalties under § 116.072 can reach $25,000 per violation identified in an inspection or compliance review.⁸

The more consequential enforcement tool is market access. When a manufacturer fails to report, the MPCA can notify retailers directly that continued sale of that manufacturer’s products is prohibited in the state. Retailers who keep stocking the items after that notice become knowing violators.² Manufacturers must also notify their own downstream sellers when a product can no longer be sold in Minnesota and provide the MPCA with a list of everyone they notified.

A Note on Drinking Water

Minnesota’s PFAS drinking water rules are a separate regime from the product bans and reporting requirements above. The Minnesota Department of Health sets Health Risk Limits and Health-Based Values for individual PFAS compounds in drinking water, and the EPA has finalized Maximum Contaminant Levels for six PFAS at the federal level, with public water system monitoring and remediation deadlines running through 2027 and 2029.⁹¹⁰ Those obligations fall on public water systems, not on product manufacturers or retailers, and they do not substitute for compliance with § 116.943 or the firefighting-foam and food-packaging statutes.

1
Minnesota Pollution Control Agency. 2025 PFAS Prohibitions
2
Minnesota Office of the Revisor of Statutes. Minnesota Code 116943 – Products Containing PFAS
3
Minnesota Office of the Revisor of Statutes. Minnesota Code 325F072 – Firefighting Foam
4
Minnesota Office of the Revisor of Statutes. Minnesota Code 325F075 – Food Packaging; PFAS
5
Minnesota Pollution Control Agency. Reporting PFAS in Products
6
U.S. Environmental Protection Agency. TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances
7
Minnesota Pollution Control Agency. PFAS in Products: Currently Unavoidable Use
8
Minnesota Office of the Revisor of Statutes. Minnesota Code 116072 – Administrative Penalties
9
Minnesota Department of Health. PFAS Standards for Drinking Water
10
US Environmental Protection Agency. Per- and Polyfluoroalkyl Substances (PFAS)