Minnesota, U.S. – Final PFAS Control Rule Adopted
Notification Requirements and Comprehensive Ban
Minnesota, U.S. has adopted the final PFAS control rule – Notification and comprehensive ban
The State of Minnesota has issued the final PFAS regulatory rule. In addition to requiring manufacturers to report information on PFAS-containing products by July 1, 2026, the rule also establishes phased, product-specific bans on PFAS to protect public health.
Minnesota Issues Final Rule on PFAS-Containing Products – What Are the Notification Requirements?
The Minnesota Pollution Control Agency (MPCA) adopted the new regulation on December 8, 2025, specifying reporting obligations and associated fees for manufacturers of PFAS-containing products.
Under the final rule:
- By July 1, 2026, manufacturers must submit reports covering all PFAS-containing products or components sold in Minnesota.
- Products introduced after July 1, 2026, must be reported by February 1, 2027.
- If there are significant product changes or new information, updates must be submitted annually by February 1.
- If no changes occur, manufacturers must still re-submit a confirmation report stating that no updates are required.
Required Reporting Information Includes:
Notification Summary
- Product Identification
Product description and applicable NAICS or SIC codes. - Chemical Information
PFAS chemical names, CAS numbers, concentration ranges in homogeneous materials, and functional use. - Contact Information
Manufacturer address and authorized representative contact details. - Confidential Business Information (CBI)
Sensitive information (e.g., specific chemical identities) may be claimed as confidential.
Whether submitted individually or as part of a group report, each manufacturer must pay a fee:
- Initial reporting fee: USD 800 per manufacturer
- 90-day reporting extension:
- Must be requested at least 30 days in advance
- Extension fee: USD 300 per manufacturer
If PFAS substances are reduced or eliminated, or if required information changes, manufacturers may voluntarily update their initial report at any time without additional fees.
Timeline for PFAS Bans by Product Category
In addition to notification requirements, Minnesota has established product-specific PFAS sales bans with the following effective dates:
Are There Any Exemptions?
Consistent with the April proposal, the final rule does not yet include determinations on “Currently Unavoidable Use (CUU)”, which remain subject to a separate rulemaking process.
However, under the exemption provisions of Amara’s Law, the following categories are exempt from reporting requirements:
- Second-hand products
- Products subject to federal PFAS regulations that pre-empt state authority
- Products already regulated under Minnesota law for PFAS in firefighting foam
- Products already regulated under Minnesota law for PFAS in food packaging
PFAS Restrictions Are a Key Focus of Future Regulation
As U.S. states such as Minnesota and Maine continue to tighten PFAS regulations—often in a fragmented and rapidly evolving manner—companies are facing unprecedented compliance challenges. Frequent regulatory updates mean that even minor amendments can have far-reaching impacts across the electronics, semiconductor, textile, and consumer goods supply chains.
SGS recommends that companies move beyond passive regulatory monitoring and adopt a “preventive compliance” strategy to stay ahead of emerging requirements.
SGS One-Stop PFAS Risk Assessment Services
Comprehensive Coverage of Compounds and Polymers
SGS integrates three core technologies—Total Fluorine (TF) testing, Targeted PFAS analysis, and the latest PFAS Verification Service—into a “PFAS 3-in-1 Testing Package”, delivering a complete, one-stop PFAS risk assessment solution.
- Breakthrough risk evaluation: Effectively addresses sensitivity limitations that traditional approaches cannot overcome.
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SGS provides comprehensive testing services and expert assessments aligned with regulatory requirements across global markets, helping you clarify product risks, plan appropriate testing scopes, and implement early compliance strategies with confidence. Contact us: rsts.tw@sgs.com