If your company asked MPCA for more time and got it, your Minnesota PFAS reporting extension moves your initial report to December 14, 2026. That sounds like plenty of time. It isn't. Supplier answers take weeks, holidays slow everything down, and the rule allows only one extension.
Here's an eight-week plan to file on time, plus advice if you missed September 15 entirely.
Key takeaways
- Extended reports are due December 14, 2026. Only one 90-day extension is allowed.
- Work backward: supplier data first, PRISM entry last.
- Report what you have by the deadline and document your outreach.
- Missed September 15 with no extension? File quickly with your best data and get advice.
Where things stand
- Initial deadline: September 15, 2026 (moved twice, from January 1 and July 1).
- Extension and waiver requests had to be postmarked by August 16, 2026.
- Approved extensions: report due December 14, 2026.
Details on the full reporting process are in our PRISM reporting guide.
The 8-week plan (from mid-October)
Week 1 (Oct 19–25): Scope
- Pull every SKU sold into Minnesota.
- Flag products likely to contain intentionally added PFAS: water-repellent, stain-resistant, nonstick, membranes, laminates, some trims.
- Confirm who your PRISM account holder is and that the account works.
Week 2 (Oct 26–Nov 1): Send supplier requests
- One standard request per supplier, listing the exact materials you buy.
- Ask: Is PFAS intentionally added? Which ones (CAS numbers)? How much? Why?
- Set a reply date 10 business days out. Use our supplier declaration template.
Week 3 (Nov 2–8): First follow-up
- Short reminder to non-responders.
- Start reading early replies. Reject vague ones politely and ask again.
Week 4 (Nov 9–15): Second follow-up and escalation
- Call or message your account manager at each slow supplier.
- Decide which gaps to fill with testing. Order TOF tests now; lab turnaround takes time.
Week 5 (Nov 16–22): Build the data set
- One row per product-component with PFAS.
- Fill identity, amount or range, and purpose. Link every value to its source.
Week 6 (Nov 23–29): Thanksgiving week buffer
- Expect slow replies. Use it to clean data and draft PRISM entries.
Week 7 (Nov 30–Dec 6): Enter in PRISM
- Enter or upload data. Pay the $800 fee if not already paid.
- Internal review by the person who will sign off.
Week 8 (Dec 7–14): Submit and archive
- Submit no later than December 11 to leave room for technical issues.
- Save a copy of the submission, the data set, and your outreach log.
If some suppliers never answer
This will happen. MPCA has said manufacturers are considered in compliance if they report all PFAS data available by the deadline and keep records of their efforts to get more. So:
- Report what you know, using total organic fluorine ranges where specifics are missing.
- Keep a log: who you asked, when, how often, and what they said.
- Keep asking after you file, and update via PRISM's copy-report feature.
See getting suppliers to respond for wording that works.
If you missed September 15 and had no extension
Don't wait. Steps:
- Talk to counsel about your exposure and approach.
- Gather what you have now, even if incomplete.
- File as soon as possible in PRISM with your best data.
- Document your outreach and your plan to complete the data.
- Fix the process so new products are checked before launch.
Don't forget the bans
Reporting is separate from the product bans. Since January 1, 2025, 11 categories, including cookware, upholstered furniture, textile furnishings, rugs and juvenile products, can't be sold in Minnesota with intentionally added PFAS. A report doesn't make a banned product legal. See our Amara's Law guide.
Common last-minute problems (and fixes)
| Problem | Fix |
|---|---|
| PRISM account holder left the company | Register a new account holder now; don't wait for December |
| Supplier gives a "PFAS-free" letter with no material names | Send back the material list and ask for a per-material answer |
| Supplier won't share CAS numbers | Ask them to report on your behalf under agreement, or use a TOF range |
| Conflicting answers from two suppliers on the same material | Ask both for test data; test yourself if needed |
| Too many SKUs to enter by hand | Group identical products and components; check PRISM's upload options |
| Unsure if a product is in scope | Check the exemption list in Minnesota Rules chapter 7026; ask MPCA |
What a good outreach log looks like
| Supplier | Materials | Sent | Follow-up 1 | Follow-up 2 | Escalation | Status |
|---|---|---|---|---|---|---|
| Example Mills | 4 fabrics | Oct 27 | Nov 3 | Nov 10 | Call Nov 13 | Received Nov 14 |
| Zipper Co | 2 zippers | Oct 27 | Nov 3 | Nov 10 | Buyer email Nov 12 | Partial: 1 of 2 |
| Trim Vendor | 6 trims | Oct 27 | Nov 3 | Nov 10 | Call Nov 13 | No reply; TOF test ordered |
Simple, dated, and easy to show anyone who asks what you did.
After December 14
Filing is the start, not the end. Plan for:
- Annual updates when products or PFAS information change.
- New products: check PFAS status before launch in Minnesota.
- The 2032 ban: every reported product-component is on your phase-out list. See Minnesota's 2032 PFAS ban.
Final-week checklist
- All received declarations read and logged
- TOF ranges entered where identities are unknown
- Data reviewed by the person signing off
- PRISM entries complete and fee paid
- Submitted by December 11 to leave buffer time
- Confirmation saved with the data set and outreach log
- Follow-up plan for missing suppliers written down
More questions
"Can we submit and then correct mistakes?" PRISM allows updates through features like copy report. File your best data on time, then correct and complete it.
"Do we have to report products we stopped selling?" Focus on products sold, offered for sale or distributed in Minnesota in scope of the rule. Ask MPCA about discontinued items if unsure.
Key terms
- Extension request: A one-time 90-day extension of Minnesota's initial reporting deadline, postmarked by August 16, 2026.
- Waiver request: A request to be excused from reporting in certain cases.
- Best available information: The data you have by the deadline, reported in good faith while you keep collecting.
- Outreach log: Your dated record of every supplier request, follow-up and reply.
- Copy report: A PRISM feature for updating an earlier report.
The bottom line
December 14 is close, but manageable with a plan. Send every supplier request this month, follow up weekly, fill gaps with TOF ranges, and submit early. A good-faith report backed by a clear outreach log is far better than a late or missing one.
How Secuabase helps
Deadline crunches are where we're most useful. We send every supplier request in one go, follow up on schedule, read every document, and build a PRISM-ready data set with a full outreach log. You review and submit.
For our first partners we run it free on one product line. Book a quick chat.
FAQ
When is the report due with an extension?
December 14, 2026.
Can I get a second extension?
The rule allows one 90-day extension. Plan to file by December 14.
What if I missed September 15 with no extension?
Get advice and file as soon as possible with your best data, plus records of your outreach.
General information, not legal advice. Confirm with MPCA. Facts checked October 2026.
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