Minnesota PFAS

Arpil 30, 2025 | Written by GreenSoft Technology, Inc.

New Rules Published for Minnesota PFAS Reporting Requirements and Fees 

Public comment period now open for rules clarifying Minnesota PFAS reporting requirements and fees

On April 21, the Minnesota Pollution Control Agency (MPCA) published a notice of intent to adopt new rules governing PFAS reporting requirements and fees for products containing intentionally added Per-and polyfluoroalkyl substances (PFAS). The proposed MPCA PFAS rules clarify Minn. Stat. § 116.943 by outlining reporting obligations and establishing a fee structure to support the administration of this new program.

The public comment period is now open and closes at 4:30 p.m. on May 21, 2025. Questions, comments, and feedback on the proposed rules may be submitted here. The full text of the proposed rules can be found here.

Minnesota PFAS reporting requirements and reporting deadline 

Any manufacturer, or group of manufacturers, that sells, offers for sale, or distributes a product in the state of Minnesota must report each product or component containing intentionally added PFAS to the MPCA. The deadline for submitting reports is January 1, 2026.

For new products introduced after this deadline, the report must be submitted prior to the product being sold. One manufacturer may submit the required information on behalf of another, provided certain conditions are met, which are listed here.

Reports must include the following information:

1. A brief description of the product or group of similar products, which must be used consistently in all future reporting updates. Manufacturers may group similar products composed of homogenous materials, provided certain conditions are met. If a product includes multiple components containing intentionally added PFAS, each component must be reported under the product name listed in the brief description. Similar components within the product may also be grouped, if specific criteria are satisfied.
2. The numeric product codes are assigned to the product.
3. The chemical name.
4. The CAS number, or if no CAS number exists, another chemical identifying number.
5. The concentration of PFAS chemicals in the product or in components made of homogenous materials. Manufacturers must report these concentrations in accordance with the ranges outlined in 7026.0030(C)(1) and (2).
6. The function that each PFAS chemical provides to the product or tis components.
7. Manufacturer information including name, address and NAICS code or SIC code.
8. Authorized representative contact information
9. Required PFAS Fees (initial report is $1000, annual update/recertification is $500)

Trade secret data, such as chemical name, chemical identifying number, and specific supply chain information may be kept confidential by request.

Annual PFAS Reporting Updates and Recertification

Updates to the report must be submitted by February 1 each year if, during the previous 12 months, any of the following occurred:

1. A significant change was made to the product.
2. New product information was provided to the manufacturer; or
3. A new product was sold, offered for sale, or distributed in or into the state.

The update must include all required information listed above.

If no update is required, the manufacturer or group of manufacturers must recertify the existing report by February 1 of each year.

Voluntary updates to the initial report can be made at any time if (1) a PFAS chemical is reduced or eliminated from a product or (2) there is a change in the required information. In these instances, voluntary updates are not subject to a fee.

Waivers, Extensions, and Exemptions

Waiver Requests: Manufacturer(s) may request a waiver for all or part of PFAS reporting requirements if the commissioner determines that equivalent information is publicly available and that accessing it does not create an undue burden. Waiver requests must be submitted annually, and the request must be submitted at least 30 days before the applicable reporting due date.

Extension Requests: A 90-day extension may be granted if it is determined that additional time is warranted to allow the manufacturer(s) to meet the reporting requirements. Extension requests must be submitted no later than 30 days before the reporting deadline, and they must include the reason for the extension, supporting documentation that substantiates the need for additional time, and a plan outlining how and when the remaining information will be submitted.

Exemptions: The following are exempt from the reporting requirements:

1. Products for which federal law regulates PFAS presence in a way that preempts state authority.
2. Products regulated under Minnesota Statutes, sections 072 or 325F.075.
3. The sale or resale of used products.
4. Products reported to the Department of Agriculture as meeting the reporting waiver criteria under Minnesota Statutes, section 943, subdivision 3, paragraph (b).
5. Information about PFAS-containing products or components provided to any federal agency that is classified under United States Code, Title 18, Section 798.

MPCA PFAS Fee Structure

A manufacturer required to submit a report must pay a fee for the submission to be deemed complete. Beginning July 1, 2027, and each odd numbered year thereafter, the unadjusted fees will be adjusted for inflation.

• Initial Report Submission: $1,000 fee.
  • If a group of manufacturers is submitting the report, or if one manufacturer is reporting on behalf of multiple manufacturers, each manufacturer must pay a $1,000 fee.
• Annual Update or Recertification: $500 flat fee.
  • If a group of manufacturers is reporting, or if one manufacturer is reporting on behalf of multiple manufacturers, each manufacturer must pay the $500 fee.
• Extension Request: $300 fee.
  • If a group of manufacturers requests an extension, each individual manufacturer must pay the $300 fee.
• Voluntary Updates: No fee required.
• Waiver Request: Manufacturer(s) submitting a waiver request must still pay the applicable fees. If the request is denied, the manufacturer(s) must submit the required report but will not be subject to additional fees.

PFAS requirements for manufacturers: supply chain data collection and due diligence

The Minnesota PFAS Regulation places significant demands on manufacturers. Affected companies must collect detailed information from their supply chain to identify PFAS within their parts and components and fulfill MPCA reporting requirements. Additionally, manufacturers must maintain records of all communications related to PFAS reporting compliance and reporting responsibility agreements for a minimum of five years after products containing intentionally added PFAS are removed from the supply chain.

GreenSoft helps you comply with new Minnesota PFAS Requirements

GreenSoft’s PFAS solution makes meeting Minnesota’s PFAS requirements effortless. Our expert data collection team persistently engages with your suppliers to collect detailed substance information for your products and components.

We validate the provided data for accuracy and completeness, and check it against the U.S. Environmental Protection Agency (EPA) Master List of PFAS Chemicals, the Organisation for Economic Co-operation and Development (OECD) list of PFAS chemicals, and any other global environmental regulations that you must comply with.

With GreenSoft, you’ll receive:

• Hands-On PFAS Data Collection: We collect PFAS data from your supply chain and deliver all the information you need to satisfy MPCA’s PFAS reporting requirements.
• Due Diligence Package: We’ll deliver records of all supplier communications so you can meet MPCA’s due‑diligence and record-keeping requirements.

• PFAS Updates and Reminders: We monitor PFAS requirements worldwide to notify you of reporting deadlines, and when regulations change or new ones arise.

Partner with GreenSoft to offload the burden of regulatory compliance, minimize risk, and stay ahead of evolving PFAS regulations—so you can keep your focus where it belongs: growing your business.