PFAS reporting is new for most brands, and the rules sound complicated. The core question is simple: who needs to report PFAS? This guide gives you a plain answer, state by state, as of October 2026.
Key takeaways
- Minnesota: manufacturers of any product with intentionally added PFAS must report.
- New Mexico: reporting starts January 1, 2027.
- Maine: reporting now only for products with a "currently unavoidable use," due by 2032.
- Washington: reporting for certain product categories since January 1, 2026.
- "Manufacturer" usually means the brand owner, not the factory.
The quick answer
You probably need to report PFAS if all three are true:
- You are the manufacturer (usually the brand owner) of a product,
- that product is sold into a reporting state (online sales count), and
- the product or any part of it contains intentionally added PFAS.
Who is the "manufacturer"?
In most state PFAS laws, the manufacturer is:
- The company whose brand is on the product, or
- If that company isn't in the US, the importer or first domestic distributor.
So a US brand that designs products and has them made in Asia is usually the manufacturer. The factory is not.
State by state
| State | Who reports | What | When |
|---|---|---|---|
| Minnesota | Manufacturers of any product with intentionally added PFAS | Product, PFAS identity, amount or range, purpose | First reports Sept 15, 2026 (Dec 14, 2026 with extension); then updates |
| New Mexico | Manufacturers of non-exempt products with intentionally added PFAS | Product, PFAS by CAS number, purpose and more | From Jan 1, 2027 |
| Maine | Only manufacturers of products with a "currently unavoidable use" | Product and PFAS details | By Jan 1, 2032 |
| Washington | Manufacturers in certain categories (e.g., footwear, cleaners, cookware) | Intentional PFAS use | From Jan 1, 2026 |
There's also a federal TSCA PFAS reporting rule focused on manufacturers and importers of PFAS and PFAS-containing articles, with deadlines that have been delayed several times. Check its current status separately.
Minnesota in more detail
Minnesota has the broadest rule. It covers any product with intentionally added PFAS, not just banned categories. A rain jacket with a PFAS membrane is reportable even though jackets aren't banned in Minnesota yet.
- Reports go through PRISM, the state's online system.
- There's a one-time $800 fee per manufacturer.
- If suppliers don't give you full data, report what you have, keep asking, and keep records.
Step-by-step: Minnesota PFAS reporting in PRISM. Got an extension? See the December 14 deadline.
New Mexico in more detail
New Mexico's reporting starts January 1, 2027, alongside its first product bans. It also has labeling rules and an exemption for certain fluoropolymers. See New Mexico PFAS Protection Act.
What goes in a PFAS report?
Typical fields:
- Product name and description
- Which part has PFAS (e.g., "membrane")
- PFAS chemical name and CAS number
- Amount or concentration range
- What the PFAS does (water repellency, nonstick, etc.)
- Your company's contact details
Most of this comes from your suppliers. That's why reporting takes weeks or months.
What if my product has no PFAS?
Then you generally don't report it. But keep proof: signed supplier declarations for each part. If a regulator or retailer asks, you can show why. See supplier PFAS declaration template.
What if I don't know?
That's the most common situation. Steps:
- List your products and their parts.
- Ask each supplier about PFAS in each part.
- Test high-risk parts if suppliers can't answer.
- Report what you find, where required.
See how to check if a product contains PFAS.
Common questions
"We only sell online. Do we still report?" Yes, online sales into the state count.
"Our retailer sells our products in Minnesota. Who reports?" Usually you, the brand owner.
"Can my supplier report for me?" Minnesota allows suppliers to report on a manufacturer's behalf under agreement. That can help when suppliers want to keep chemistry confidential.
"Is reporting the same as being banned?" No. Reporting is disclosure. Bans are separate. A banned product shouldn't be sold at all.
"Does reporting in one state cover others?" MPCA says PRISM reporting may also meet other states' requirements. Confirm with each state.
Key terms
- Manufacturer: Usually the brand owner; sometimes the importer.
- Intentionally added PFAS: PFAS added on purpose for a function.
- PRISM: Minnesota's PFAS reporting system.
- CAS number: A chemical's unique ID.
- Extension: Minnesota's one-time 90-day extra time for initial reports.
The bottom line
If you're the brand owner and any part of your product contains intentionally added PFAS, and you sell into Minnesota, New Mexico (from 2027) or certain Washington categories, you likely need to report. Start by asking your suppliers, and keep every answer.
How Secuabase helps
We collect the supplier data you need, check it, and prepare report-ready data for Minnesota and other states, with a full record of every request. Your team reviews and submits.
For our first partners we run it free on one product line. Book a quick chat.
FAQ
Who has to report PFAS in Minnesota?
Manufacturers of any product with intentionally added PFAS sold there.
Is the manufacturer the brand or the factory?
Usually the brand owner.
Do I report if my product has no PFAS?
Generally no, but keep proof.
General information, not legal advice. Facts checked October 2026.
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