Minnesota PFAS reporting is the first requirement in the US that asks manufacturers to disclose intentionally added PFAS across all products. The initial deadline was September 15, 2026, and manufacturers with an approved extension must file by December 14, 2026. After that, reports must be kept up to date.
This guide walks through who must report, what data you need, how PRISM works, and how to handle supplier gaps.
Key takeaways
- Report every product sold in Minnesota with intentionally added PFAS, in any category.
- You need product description, PFAS identity, amount or range, and purpose.
- Total organic fluorine can stand in when exact PFAS are unknown.
- $800 one-time fee per manufacturer.
- Incomplete supplier data: report what you have, document your outreach, update later.
Who must report
Any manufacturer of a product that:
- is sold, offered for sale or distributed in Minnesota (online sales count), and
- contains intentionally added PFAS in the product or any component.
"Manufacturer" usually means the brand owner. If the brand owner isn't in the US, the importer or first domestic distributor may be responsible. Reporting is not limited to the 11 banned categories; it covers any product with intentionally added PFAS, like a jacket with a fluorinated membrane.
Some products and situations are exempt from reporting under Minnesota Rules chapter 7026. Check the exemption list before assuming you're in or out.
Key dates
| Date | What |
|---|---|
| January 2026 | PRISM opened to all manufacturers |
| April 15, 2026 | MPCA moved the deadline from July 1 to September 15, 2026 |
| August 16, 2026 | Postmark deadline for extension and waiver requests |
| September 15, 2026 | Initial reports due |
| December 14, 2026 | Due date for manufacturers granted a 90-day extension |
| Ongoing | Annual updates when products or PFAS information change, and for new products |
The data you need, per product
- Product description. Name, model, product category, and the brand.
- Component detail. Which component contains PFAS (e.g., "membrane," "zipper tape").
- PFAS identity. Chemical name and CAS number where known.
- Amount. Concentration of each PFAS. If unknown, total organic fluorine may be used. Ranges are allowed.
- Purpose. What the PFAS does: water repellency, nonstick, stain resistance, processing aid, etc.
- Manufacturer details. Company name, address, contact person.
Most of this lives with your suppliers, not in your office. That's why preparation takes months.
Step-by-step: preparing your report
Step 1: List products sold in Minnesota
Pull every SKU shipped to Minnesota addresses or listed for sale to Minnesota buyers. For most national brands, that's the whole catalog.
Step 2: Break products into components
Use your bill of materials. See PFAS bill of materials mapping.
Step 3: Ask suppliers about PFAS
Send each supplier a standard form asking whether PFAS was intentionally added to the material, which PFAS, how much, and why. See our supplier declaration template.
Step 4: Chase and log
Follow up on a schedule (for example, day 7, day 14, day 21). Log every request and reply. See getting suppliers to respond.
Step 5: Check every answer
Look for vague, unsigned or off-topic replies. A statement that "we comply with REACH" doesn't answer the PFAS question.
Step 6: Fill gaps
Where suppliers can't give exact PFAS identities, consider a total organic fluorine test so you can report a TOF-based range. See TOF testing explained.
Step 7: Build the data set
One row per product-component with PFAS, mapped to PRISM's fields. Keep the source document for every value.
Step 8: Register and submit in PRISM
Register an account (name, title, phone, email, company address and NAICS/SIC code), enter or upload your data, and pay the $800 fee. MPCA offers a reporting guide, a supplemental guide for tricky scenarios, how-to videos and office hours.
Handling missing supplier data
This is the biggest pain point. MPCA's position, per its supplemental guidance: a manufacturer is considered in compliance if it reports all PFAS data available by the deadline and keeps records of its efforts to get more. PRISM's "copy report" feature lets you update later.
So the goal isn't perfection on day one. It's a good-faith report backed by a clear outreach trail.
After you file: annual updates
Reporting isn't one-and-done. Expect to update when:
- you launch a new product with intentionally added PFAS in Minnesota,
- a supplier gives you new PFAS information,
- you change a material or formula.
Build a simple trigger: any new SKU or material change runs through your PFAS check before launch.
Common mistakes
- Reporting only banned categories. All products with intentionally added PFAS are reportable.
- Ignoring components. The PFAS is usually in one part, not the whole product.
- No purpose field. If you can't say why PFAS is there, ask again.
- No records. Without an outreach log, incomplete data looks like no effort.
Example data row
Here's what one product-component entry might look like before you enter it in PRISM:
| Field | Example |
|---|---|
| Product | Alpine Shell Jacket, Men's (SKU AS-M-26) |
| Component | Membrane |
| PFAS | Polytetrafluoroethylene (PTFE) |
| CAS number | 9002-84-0 |
| Amount | Range provided by supplier |
| Purpose | Waterproof-breathable barrier |
| Source | Supplier declaration, Example Laminates, signed 2026-08-14 |
The last row isn't a PRISM field, but keep it in your own data set. When someone asks where a number came from, you'll know.
Group and supplier reporting
Minnesota's rule allows groups of manufacturers to report together and allows suppliers to report on a manufacturer's behalf under agreement. This helps when a supplier won't share confidential chemistry with you but is willing to report it directly. If you use this route, keep a copy of the agreement and confirmation of what was filed.
Reporting checklist
- PRISM account holder confirmed and active
- All Minnesota SKUs listed, including online-only items
- Components with intentionally added PFAS identified
- Identity, CAS number, amount or range, and purpose filled for each
- Source document linked for every value
- Outreach log kept for every supplier
- $800 fee paid
- Copy of the submission saved
- Annual update trigger set for new products and changes
Key terms
- Reporting waiver: A request to be excused from reporting in certain situations, filed with MPCA.
- 90-day extension: A one-time extension of the initial deadline; approved reports are due December 14, 2026.
- CAS number: A unique ID for a chemical substance, used to identify PFAS in reports.
- Concentration range: An allowed way to report PFAS amounts instead of exact numbers.
- Annual update: A report change triggered by new products or new PFAS information.
How Secuabase helps
We run the supplier outreach, chase non-responders, read each document, test-match where needed, and deliver a PRISM-ready data set with every value traced to its source. Your officer reviews and submits; we never file or sign for you.
For our first partners we run it free on one product line. Book a quick chat.
FAQ
Who must file a Minnesota PFAS report?
Any manufacturer of a product sold in Minnesota with intentionally added PFAS, including online sales.
What is PRISM?
The PFAS Reporting Information System for Manufacturers, MPCA's online reporting system.
What if suppliers didn't give data?
Report what you have, keep asking, keep records, and update as data arrives.
General information, not legal advice. Confirm requirements with MPCA. Facts checked October 2026.
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