Minnesota has again delayed its first-in-the-nation reporting deadline for per- and poly-fluoroalkyl substances (PFAS) in products. On April 15, 2026, the Minnesota Pollution Control Agency (MPCA) announced that it is extending the deadline for initial PFAS in products reports from July 1, 2026, to September 15, 2026. MPCA also released extension and waiver request forms, set a new postmark deadline for those requests, and announced additional support materials and system updates to its reporting portal, the PFAS Reporting Information System for Manufacturers (PRISM).
The reporting obligation remains significant. Under Minnesota’s PFAS in products statute and final rules adopted in December 2025, manufacturers of products with intentionally added per- and polyfluoroalkyl substances (PFAS) that are sold, offered for sale, or distributed in Minnesota must submit reports to MPCA and pay a one-time $800 reporting fee. MPCA says the extension is intended to give manufacturers more time to coordinate with suppliers, become familiar with PRISM, and use agency support resources.
Background
Minnesota’s PFAS in products law, commonly known as Amara’s Law, requires manufacturers to report products or product components containing intentionally added PFAS that are sold, offered for sale, or distributed in the state. MPCA published reporting rules partially implementing Amara’s Law in December 2025 (see B&D’s alert here). Those rules require reporting of, among other things, a product description, the PFAS chemicals used in the product or its components, PFAS concentration, PFAS function, and manufacturer contact information.
For many companies, especially those relying on complex supply chains, compiling that information remains a major undertaking. MPCA’s updated guidance recognizes that manufacturers may need to submit reports based on the best available information by the deadline, continue seeking complete information from suppliers, and document those efforts.
Key Reporting Updates
1. Initial Reporting Deadline Extended to September 15, 2026
MPCA extended the initial reporting deadline from July 1, 2026, to September 15, 2026. The agency says the additional time will help manufacturers gather supplier information, establish supplier reporting arrangements where appropriate, become familiar with PRISM, and use available technical support.
MPCA’s timeline now lists September 15, 2026, as the due date for initial reports and December 14, 2026, as the deadline for manufacturers that receive extensions.
2. Extension and Waiver Request Forms are Now Available, With an August 16, 2026 Postmark Deadline
The rules allow manufacturers to seek either a 90-day extension of the reporting deadline or a waiver for products covered by publicly available records containing substantially equivalent information to the required reporting elements. MPCA has now posted forms for both types of requests (extension requests; waiver requests). According to the agency, extension requests should be brief and focused, and need not include extensive supporting documentation, while waiver requests need only show that equivalent PFAS-in-product information is publicly available and verifiable.
Both forms, along with the applicable fees, must be postmarked by August 16, 2026. If MPCA grants an extension request, the manufacturer’s report will be due December 14, 2026.
3. Additional PRISM Support and System Updates
MPCA says that it will release short instructional videos for common reporting tasks this spring. The agency also says that when technical issues cannot be resolved by email, it may invite users to virtual “office hours” with screen sharing. In addition, MPCA says PRISM 1.2 is expected in late April 2026, with improvements including direct template download, reminders regarding macros and unsaved work, and other usability enhancements.
Next Steps
While the extension gives manufacturers additional time, they should not pause compliance efforts. Companies should continue collecting PFAS information across their product portfolios, documenting supplier outreach, evaluating whether another manufacturer may report on their behalf, and assessing whether an extension or waiver request is appropriate.
MPCA’s current guidance makes clear that manufacturers remain responsible for reporting even where suppliers are unresponsive. Where supply-chain information is incomplete, manufacturers should report the information they have by the deadline using the options available in PRISM, continue requesting additional information, and maintain documentation of those efforts. In announcing the extension, MPCA stated that it will consider a manufacturer in compliance with the initial reporting requirements if the manufacturer timely reports all available PFAS information, retains due diligence documentation, and provides that documentation to the agency upon request.
Notably, Minnesota’s extended reporting deadline does not conflict with EPA’s current timeline for PFAS reporting under TSCA Section 8(a)(7), which EPA recently delayed again. For additional discussion, see our updated alert here.
