School’s Out for Summer, but Minnesota’s Amara’s Law Still Assigns PFAS Reporting Homework

Minnesota’s comprehensive per- and polyfluoroalkyl substances (PFAS) pollution prevention law, commonly referred to as Amara’s Law, includes a product reporting requirement with broad reach and deadlines later in 2026. It requires manufacturers or groups of manufacturers to report products containing intentionally added PFAS that are sold, offered for sale, or distributed in Minnesota. The Minnesota Pollution Control Agency (MPCA) has extended the initial reporting deadline to Sept. 15, 2026, and reports must be submitted through the PFAS Reporting Information System for Manufacturers (PRISM). Manufacturers may apply by Aug. 16, 2026, for a one-time extension of the initial reporting deadline until Dec. 14, 2026.

Amara’s Law was recently amended to narrow its scope, excluding products manufactured before July 1, 2023, from reporting. While this amendment may reduce the reporting burden for some companies, many still face considerable work related to supply chain assessments, trade secret protection, and other risk mitigation steps that may be warranted following public disclosure.

Who Must Report

A manufacturer, or group of manufacturers, must report if the product or product component meets all the following criteria: it was manufactured after July 1, 2023; it is sold, offered for sale, or distributed in Minnesota, including through online sales into the state; and it contains intentionally added PFAS. The reporting obligation may apply across the product supply chain, including manufacturers, brand owners, importers, or first domestic distributors, depending on the circumstances and applicable statutory definitions.

What Must Be Reported

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.

Reporting Platform, Fee, and Confidentiality

Reports must be submitted through PRISM. Each manufacturer must also pay a one-time flat fee of $800 to support implementation costs. MPCA has indicated that reported information will generally be publicly accessible following a review period, except for information protected as a trade secret. Manufacturers may request waivers, extensions, and trade secret protection where available under the rules.

Key Deadlines

Practical Takeaways

• Companies selling products into Minnesota should promptly identify products and components manufactured after July 1, 2023, that may contain intentionally added PFAS.
• Supply chain outreach is likely necessary, particularly where PFAS information is held by upstream suppliers or component manufacturers.
• Businesses should document efforts to obtain missing supplier data and consider whether supplier reporting arrangements, extensions, waivers, or trade secret requests are appropriate.
• Companies should prepare for public disclosure of most submitted information, including the association of specific products with PFAS.
• Companies should monitor Minnesota rulemaking on which uses of PFAS will be determined to be “currently unavoidable” and exempt from the Jan. 1, 2032, prohibition, or assess steps needed to eliminate intentionally added PFAS from their supply chains to achieve compliance.