PFAS product reporting: What manufacturers inside and outside Minnesota need to know
PFAS are banned on the surfaces of toys sold or distributed in Minnesota but must still be reported when they are present in internal or electronic components.
Article summary: Minnesota’s per- and polyfluoroalkyl substances (PFAS) product reporting rule doesn’t just affect manufacturers based in Minnesota—it applies to any manufacturer that sells or distributes products in the state. The rule builds on recent product bans but introduces a broader and more detailed set of requirements. Manufacturers may need to take a closer look at how PFAS are used across products and their components, often in ways that aren’t immediately obvious. The level of detail required—combined with broad definitions and evolving guidance—can make reporting as much a data and supply-chain effort as a regulatory one. In this article, we walk through key considerations and practical steps to help manufacturers prepare for the 2026 deadline and subsequent annual reporting deadlines.
Many manufacturers are already familiar with Minnesota’s PFAS requirements—especially those tracking the 2025 product bans. But the upcoming reporting deadline is catching companies off guard for a different reason: it’s broader and more detailed than many expected.
The 2026 reporting deadline is as much a supply chain and product data challenge as a regulatory one.
A new PFAS product reporting rule adds requirements—and associated fees—for manufacturers of products that contain intentionally added PFAS and are sold, offered for sale, or distributed in Minnesota. The initial reporting deadline, now extended to September 15, 2026, is just over two months away. However, this is not a one-time reporting exercise—subsequent reports are due annually on February 1. This makes PFAS reporting an ongoing compliance obligation rather than a one-time deadline.
While many manufacturers are already preparing for these requirements, the scope of reporting reflects a broader set of considerations than many initially expected.
Reporting goes beyond whether a product falls within one of the 11 banned categories implemented in 2025—or whether PFAS are present in an obvious coating, textile treatment, or other surface application. In practice, reporting may still apply if:
- A product is sold only through a website
- It’s manufactured outside Minnesota, or outside the United States
- PFAS are present only in an internal or electronic component
That breadth, combined with Minnesota’s expansive PFAS definition, makes the 2026 reporting deadline as much a supply chain and product data challenge as a regulatory one.
There are exemptions—for example, federally regulated products and used products—but these are relatively narrow compared to the overall reporting scope.
Reporting vs. bans: Distinct but related requirements
Minnesota is moving toward a broader prohibition on products containing intentionally added PFAS. When fully implemented in 2032, PFAS-containing products will not be available for sale in Minnesota, except those the Minnesota Pollution Control Agency (MPCA) determines to be a currently unavoidable use (CUU), which is still under rulemaking.
Even if a product is eventually exempt from the ban through a CUU or another pathway, reporting may still be required.
It’s important to keep in mind: product bans and reporting requirements are separate and distinct. Even if a product is eventually exempt from the ban through a CUU or another pathway, reporting may still be required.
A reporting waiver request form is available if “substantial public information” is accessible, but it must be submitted annually and is separate from CUUs and product bans. Manufacturers can also request a 90-day extension of the September reporting deadline by submitting an extension request form before August 16 and paying a $300 fee.
One area that often causes confusion: internal and electronic components. These components may not be banned under the 2025 sales prohibition—but they still must be reported. For example, PFAS are banned from “but are currently allowed when used in internal or electronic components (for instance, wiring inside an electronic game). In other words, even if internal components are allowed under the ban, they must still be reported.
Why internal components are a common blind spot
The rule defines a component as “a distinct and identifiable element or constituent of a product.” MPCA guidance clarifies that this includes elements that may not be visible or obvious in the finished product.
That distinction matters—especially for complex products.
A manufacturer may not be able to report simply at the level of “car radio,” “pump,” or “control panel.” If PFAS are tied to a circuit board, screen film, wire coating, gasket, or other identifiable part, each may require its own entry. In practice, complex products may need multiple reporting entries for separate PFAS-containing components.
Barr has helped clients work through Toxic Substances Control Act (TSCA) PFAS reporting and PFAS chemical usage screening and review. While those efforts provide a strong starting point, they’ve often focused on raw or imported PFAS-containing materials.
Many manufacturers may now need to take a closer look at individual product components.
What to expect from reporting requirements
The MPCA is using the PFAS Product Reporting Information System for Manufacturers (PRISM) to collect and display reported information—and the level of detail required may surprise manufacturers.
Minnesota’s reporting framework is not simply asking whether a finished product contains PFAS. Instead, reporting may need to take into account the component, PFAS chemical, function, and concentration.
For example:
| Component | If four components contain the same intentionally added PFAS, each component may need its own reporting entry in PRISM. |
| PFAS chemical | If one component contains two PFAS, both PFAS need to be identified in separate entries (i.e., two entries for one component). |
| Function | If a single PFAS serves more than one function in the same component, each use may need to be reported as a separate entry. |
| Concentration | Manufacturers must also report the concentration of each PFAS, if available. |
In practice, companies should organize information to address four key questions:
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- Where are PFAS used?
- Which PFAS are present?
- What functions do they serve?
- At what concentrations are they present?
Minnesota’s PFAS definition: Broader than many standard lists
Minnesota defines PFAS broadly as fluorinated organic chemicals containing at least one fully fluorinated carbon atom.
Product teams may be familiar with specific compounds like PFOA or PFOS, or PFAS lists used in environmental testing. But Minnesota’s definition goes beyond a standard lab analyte list or a short supplier questionnaire.
As a result, PFAS may show up in places that are easy to overlook, including:
| Coatings | Gaskets and seals |
| Membranes | Wire insulation |
| Circuit boards | Lubricants |
| Films | Surface treatments |
| Packaging | Replacement parts |
This shifts the question from “Does this product have PFAS?” to: “Are intentionally added PFAS present anywhere in the product or in its components?”
What to do when supplier information is incomplete
Incomplete supply chain information does not exempt a manufacturer from reporting and recordkeeping obligations.
MPCA reporting guidance recommends that manufacturers:
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- Report the information they have by the deadline
- Continue requesting missing information
- Update reports as new data becomes available
- Maintain documentation of those efforts
If a supplier confirms PFAS are present but can’t identify the specific chemical, PRISM includes a “PFAS present but unknown at this time” option. However, manufacturers are still expected to continue pursuing that information to document their due diligence.
In many cases, the process of gathering information is just as important as the information itself.
Manufacturers should be able to document:
- What they asked
- Who they asked and when
- How they followed up
- What information was received
- What remains unknown
- Whether another party is reporting on their behalf
These due diligence records must be maintained for at least five years.
What manufacturers should do now
Manufacturers may have some flexibility in how they organize reports.
MPCA guidance allows similar products or components to be grouped if they differ only in superficial ways (such as color or size), but share the same form, function, and PFAS-use profile. The rule also allows reporting by a group of manufacturers—for example, through an industry association, brand owner, supplier group, or other authorized representative.
The most practical first step is to start before the reporting deadline feels urgent. In addition to preparing for the September 2026 deadline, manufacturers should plan for ongoing annual reporting. This reinforces the need to track PFAS use not only historically but in current and future products.
Manufacturers can begin by:
- Identifying products entering Minnesota commerce
- Screening products, components, and integral packaging for intentionally added PFAS
- Asking suppliers targeted questions (keeping in mind PFAS may not be disclosed unless specifically requested)
- Following up with suppliers when PFAS are suspected or commonly used
- Evaluating opportunities to group products or components, or collaborate with other manufacturers on reporting
It’s also important to:
- Use Minnesota’s broad PFAS definition when communicating with suppliers
- Document all requests, responses, and non-responses
- Build a reporting file that can be updated as more becomes available
If you’re still sorting through what this means for your products or supply chain, Barr’s PFAS team can help you take the next step. Contact our team and learn more about our PFAS experience.
About the authors
Casy Fath, senior geologist, has more than a decade of experience with contaminated site investigation and cleanup for a variety of soil and groundwater remediation projects. His experience includes leading investigations at sites with historical releases of PFAS, chlorinated solvents, metals, and other contaminants of concern. He has expertise with all phases of investigation and cleanup under the Resource Conservation and Recovery Act (RCRA) Corrective Action, Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), and similar programs in several states. He has recent experience addressing PFAS in stormwater, wastewater, soil, groundwater, surface water, and within industrial processes.
Gina Greenleaf, senior chemical engineer, has 19 years of experience helping clients comply with regulatory requirements for air, water, waste, and chemical management. She provides air quality permitting and compliance support; prepares and audits Emergency Planning and Community Right-to-Know Act (EPCRA) reports; and compiles Spill Prevention, Control, and Countermeasure (SPCC) plans and Stormwater Pollution Prevention Plans (SWPPPs). Gina supports clients with PFAS reporting compliance under the Toxic Substances Control Act (TSCA) Section 8(a)(7) and Toxic Release Inventory (TRI) reporting rules, including assessing reporting obligations, assisting with information gathering, and documenting due diligence efforts. Her project work primarily focuses on mining, ethanol, and manufacturing.
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Barr provided a desktop assessment of PFAS use in a manufacturing client’s operations. The client gained a snapshot of the potential PFAS-associated risks in its operations. As a result, the manufacturing client was able to assess whether certain chemicals used in the manufacturing process could be discontinued or modified. The information gathered also prepared the client for emerging PFAS regulations.
Statewide study on PFAS in groundwater at Minnesota landfills
Barr helped a coalition of landfill owners and operators gather data about the presence and concentration of certain PFAS chemicals in groundwater at Minnesota landfills. The study involved sampling at 48 landfills, lab coordination, online surveys, and a data quality review. The study report provides valuable information on upgradient vs. downgradient landfills, bottom-liner effectiveness, and methods for identifying potential releases.
PFAS-impacted drinking water response and treatment plant design
Barr completed this award-winning treatment plant design for PFAS-impacted drinking water in response to the Minnesota Department of Health’s 2017 update of health-based advisory values (HBVs). The plant, which came online in 2021, allows the City of Bemidji to stay in compliance with the state’s drinking water regulations.
