On December 8, 2025, the Minnesota Pollution Control Agency (MPCA) published in the Minnesota State Register a final rule regarding per- and polyfluoroalkyl substances (PFAS) in products reporting and fees. MPCA revised the proposed rule to correct defects identified by an August 2025 administrative law judge’s (ALJ) report. MPCA also made other non-substantial changes. Under the final rule, manufacturers of products containing intentionally added PFAS are required to report certain information by July 1, 2026.
Changes to the Proposed Rule
As reported in our September 26, 2025, blog item, the ALJ report on the proposed rule concluded that the proposed rule package must be disapproved for a procedural reason: MPCA failed to include an assessment of the cumulative effect of the proposed rule with federal regulations on PFAS reporting. MPCA’s October 27, 2025, letter to the Interim Chief ALJ includes an assessment of the cumulative effect of Minnesota’s reporting rule with other federal and state regulations related to the purpose of Minnesota’s rule. MPCA “expects that there will be additional effort needed to report Minnesota-specific requirements, but also some reduced burden for reporting under other jurisdictions and other provisions in Amara’s Law.” MPCA notes that some manufacturers subject to the rule may also be required to report to other jurisdictions, such as the U.S. Environmental Protection Agency (EPA) under the Toxic Substances Control Act (TSCA) Section 8(a)(7) reporting rule for PFAS. MPCA “anticipates that this will result in limited cumulative effects[, however,] because of differences in the specific information required under those other regulations.”
The ALJ report also cited other defects in the proposed rule. The final rule includes revisions to correct those defects, as well as other changes. According to MPCA, the final rule provides details and flexibility for manufacturers, including:
- Group reporting options;
- Reporting ranges of PFAS concentrations instead of exact amounts; and
- Waiver, extension, and trade secret requests.
The final rule sets a one-time flat fee of $800 per manufacturer, reduced from $1,000 in the proposed rule. The final rule, additional information, and a sign-up for technical updates on reporting PFAS in products are available on the MPCA’s Reporting PFAS in products web page.
PFAS Reporting Information System for Manufacturers
According to MPCA, the online system that manufacturers will use to report, called the PFAS Reporting Information System for Manufacturers (PRISM), “is now in the final stages of review with a planned soft launch in December to a limited group of manufacturers.” MPCA states that PRISM will be available to all manufacturers in January 2026. MPCA will announce PRISM’s launch through its GovDelivery service and on its website.
MPCA based PRISM on the High Priority Chemicals Data System operated by the Interstate Chemicals Clearinghouse, which is “already familiar to many manufacturers.” MPCA notes that the reported data “may also meet reporting requirements for other states.” Reported data that are not requested to be maintained as trade secret data will be available to the public after MPCA reviews and publishes the information in PRISM. According to MPCA, report publishing “will be an ongoing process as reports are submitted.”
