On April 15, 2026, the Minnesota Pollution Control Agency (MPCA) announced a second extension of the initial PFAS products reporting deadline, moving it from July 1, 2026 to September 15, 2026. Upon completion of the initial report, subsequent annual reports are due each February 1. Manufacturers unable to meet the deadline may apply for a single 90-day extension (to December 14, 2026).
Background
Under Minnesota's PFAS pollution prevention law, commonly known as "Amara's Law," manufacturers who sell, offer for sale, or distribute products in the state — including products sold online only-are required to report on intentionally added PFAS (per- and polyfluoroalkyl substances) in those products and pay a fee. Signed into law in May 2023, the legislation sets a goal of eliminating all non-essential uses of PFAS in the state by 2032.
Reporting Requirements
Under Minn. Stat. 116.943, subd. 2, reports must include:
- A product description;
- The purposes/functions that PFAS serve in the product;
- The amount of each type of PFAS;
- Other relevant information.
Flexible Reporting Arrangements
Following a two-year rulemaking process, Minnesota has adopted accompanying rules that provide manufacturers with greater convenience and flexibility:
- Grouping of similar products for reporting purposes;
- Allowing a group of manufacturers to report jointly;
- Reporting ranges of PFAS concentrations instead of exact amounts;
- Waiver, extension, and trade secret protection request mechanisms;
- A one-time flat fee of USD 800 per manufacturer to cover implementation costs.
PRISM Reporting System
MPCA has launched the PFAS Reporting and Information System for Manufacturers (PRISM), developed on the basis of the High Priority Chemicals Data System already familiar to many manufacturers. Reported data that is not claimed as a trade secret will be made publicly available after MPCA review. Submitting reports through PRISM may simultaneously satisfy reporting requirements of Minnesota and certain other states.
Timeline
| Date | Milestone |
| May 2023 | Amara's Law signed into law |
| 2023–2025 | PFAS reporting and fees rulemaking process; manufacturers gather information |
| Fall 2025 | Rulemaking finalized |
| December 2025 | PRISM enters soft launch for final review |
| January 2026 | PRISM 1.0 available to all manufacturers |
| February 2026 | PRISM 1.1 with enhancements available |
| April 2026 | Updated support documents, extension and waiver request forms, and PRISM 1.2 available |
| August 16, 2026 | Postmark deadline for extension and waiver requests |
| September 15, 2026 | Initial reports due |
| December 14, 2026 | Reports due for manufacturers receiving extensions |
| February 1 each year | Annual updates due when required |
Implications and Recommendations
The regulation applies to all products containing intentionally added PFAS sold in Minnesota, including cosmetics and personal care products. Affected companies are advised to proactively screen product formulations for PFAS ingredients, establish information-sharing mechanisms with suppliers, and register for a PRISM account in advance to familiarize themselves with the reporting process.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
Our Services
- The United States Agent
- The United States FDA Cosmetic Facility Registration
- The United States FDA Cosmetic Product Listing
- The United States FDA OTC Drug Registration
- The United States Color Additive Batch Certification
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- International Cosmetic Ingredient Name (INCI) Application
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