Minnesota Scales Back PFAS Disclosure Rules for Legacy Products

Perkins Coie
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Perkins Coie

On May 26, 2026, Governor Tim Walz signed a newly enacted budget bill (SF 4612) that significantly narrows Minnesota’s chemical disclosure requirements.

In a major legislative compromise, manufacturers are now exempt from reporting products or components manufactured before July 1, 2023. While the upcoming autumn compliance deadlines remain in place, this change offers substantial relief to companies managing older inventories and legacy replacement parts.

The Amendment

The bill (enacted as 2026 Minn. Laws, ch. 127, art. 14, § 4), alters the scope of Minn. Stat. § 116.943. Previously, the state required companies to disclose intentionally added per- and polyfluoroalkyl substances (PFAS) for all items sold in Minnesota, regardless of their production date.

Under the new framework, companies must submit a disclosure to the Minnesota Pollution Control Agency (MPCA) only if the product meets all three of the following conditions: (1) it was manufactured after July 1, 2023; (2) it is sold, offered for sale, or distributed within Minnesota; and (3) it contains intentionally added PFAS.

This amendment represents a practical compromise. While businesses initially sought a deadline extension to navigate rulemaking timelines and PRISM, the MPCA’s new electronic reporting portal, lawmakers opted instead to narrow the scope of regulated goods. The legislature recognized that tracking chemical data for legacy components presents a substantial administrative challenge. By exempting these older items, the law eases the compliance burden on businesses while fully preserving Minnesota's environmental goals.

Firm Compliance Deadlines

Although the reporting scope has narrowed, the submission timeline remains unchanged:

  • August 16, 2026: Requests for reporting extension and waivers must be postmarked on or before this date.
  • September 15, 2026: Initial PFAS product disclosures must be submitted via the PRISM portal.
  • December 14, 2026: Final deadline for companies that request and obtain a formal 90-day filing extension.
  • February 1, each year: Annual updates due when required.

Looking Ahead

To align operations with this new statutory boundary, compliance teams should audit their product and product component production dates and focus chemical tracing efforts on newer product lines manufactured after the July 1, 2023, cutoff date. Compliance teams should also try to access the PRISM interface early to resolve potential data-entry friction well ahead of the September 15 reporting deadline.

Minnesota remains committed to its long-term goal of phasing out all nonessential PFAS use by 2032. The MPCA views these initial disclosure reports as a critical foundation for developing safer chemical alternatives, informing consumers, and preventing environmental pollution. Consequently, early and accurate data management remains essential for compliance.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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