MPCA Extends PFAS Product Reporting Deadline by Six Months

Manufacturers who sell, offer for sale or distribute within Minnesota products that contain intentionally added per- or polyfluoroalkyl substances (PFAS) now have until July 1, 2026, to submit information on those products to the Minnesota Pollution Control Agency (MPCA) commissioner. This is a six-month extension to the January 1, 2026, deadline originally established under Minn. Stat. § 116.943, subd. 2(a).

MPCA had previously announced its intent to extend the deadline in response to comments it received on its proposed PFAS product reporting and fee rules, but it did not provide a date certain for the new deadline at that time. (See Fredrikson’s previous summaries of the proposed rules, the hearing on the rules and MPCA’s responses to comments). MPCA announced the new deadline on July 23, 2025, invoking the commissioner’s statutory authority to do so under Minn. Stat. § 116.943, subd. 3(d).

MPCA provided two justifications for the deadline extension. The first was to allow manufacturers additional time to enter agreements with suppliers to provide MPCA with the required information on the manufacturers’ behalf, as envisioned under MPCA’s proposed reporting rules. The second was to allow reporters of all stripes time to become acquainted with the new reporting platform MPCA intends to introduce sometime in Fall 2025.

Other aspects of MPCA’s July 23 announcement, however, suggest MPCA will not be adopting other changes to the proposed rules manufacturers had advocated, such as relaxing the due diligence standard for obtaining supplier information or allowing reporting on PFAS content at the “product” level rather than the “component” level. MPCA’s first justification for the deadline extension, i.e., to allow more time to work with suppliers on reporting agreements, appears to underscore its expectation that manufacturers work closely with their suppliers to gather the mandatory product information by the new deadline. Similarly, MPCA notes in its announcement that “manufacturers will have had three full years to prepare to report on PFAS in products” between passage of the underlying statute and the new reporting deadline, which suggests MPCA will show little tolerance for claims that a manufacturer did not have adequate time to obtain and provide information on its products from its suppliers.

MPCA’s announcement does not address whether MPCA still intends to finalize and adopt by January 1, 2026, its proposed PFAS reporting and fee rules or whether that deadline also will be pushed back consistent with the new reporting deadline. Regardless, Fredrikson’s Environmental Law Group will continue to monitor and report on developments in MPCA’s PFAS product reporting requirements. Please contact us if we may be of assistance with this or any other environmental law need.