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Missed Minnesota’s PFAS deadline? What to do now

Minnesota’s first PFAS report was due September 15, 2026, or December 14 with an extension. If you sell products with intentionally added PFAS there and haven’t filed, the way forward is short: file, pay the fee and keep the record.

Checked against the rule text on October 15, 2026.

Where things stand

This is a new law, and the first deadline moved twice. The statute set January 1, 2026; the final rule moved it to July 1, 2026, and Minnesota then moved it to September 15, 2026 (Minn. R. ch. 7026). The reporting system, PRISM, opened on January 30, 2026.

The Minnesota Pollution Control Agency (MPCA) hasn’t published a cutoff for late reports, or said how it will treat them. As of October 15, 2026 we found no public statement from MPCA on late filers or enforcement. If you were granted the 90-day extension, your date is December 14, 2026.

What the penalty law says

Missing the report or the fee is handled under Minnesota’s general penalty statute (Minn. R. 7026.0030, subp. 3):

  • The agency can issue a penalty order of up to $25,000 “for violations identified during an inspection or other compliance review.” That’s a cap per order, not per product (Minn. Stat. 116.072, subd. 2(a)).
  • The same law generally requires the penalty to be forgiven once the violation is corrected. The exception is a repeated or serious violation, where the commissioner can make it non-forgivable (subd. 5).
  • If the state goes to court instead, a judge can impose up to $15,000 a day (Minn. Stat. 115.071, subd. 3).
  • The commissioner can ask for test results, due within 30 days (Minn. Stat. 116.943, subd. 4(a)).
  • A store the state has notified about an unreported product can’t keep selling it (subd. 2(d)).

In plain terms, correction counts. A report filed now is the correction. Read the Minnesota duty and penalties in full.

Check what you need to report

The report covers every product sold in Minnesota with intentionally added PFAS in any amount, including in its components (Minn. Stat. 116.943). The statute has no carve-out for fluoropolymers, so PTFE coatings and ePTFE membranes count. Two limits:

  • Products made before July 1, 2023 are excluded, under a 2026 amendment.
  • Cookware, ski wax, upholstered furniture, textile furnishings and several other categories with intentionally added PFAS have been banned since January 1, 2025. They aren’t reported; they can’t be sold.

Filing late, step by step

  1. Register in PRISM. Create your company’s account through MPCA’s PFAS reporting page. A consultant can file for you by requesting access through PRISM’s “Associations” feature; you stay responsible for the report.
  2. Gather supplier information. Ask each supplier about each material. Our free declaration template has the wording. Where an answer hasn’t come back, PRISM accepts “PFAS present but unknown at this time,” “Function unknown at this time” and a range of “Unknown” (MPCA PRISM guide).
  3. Group your products. Products that differ only by color or size, with the same PFAS, function and range, can share one entry.
  4. Enter and submit. Brand, product model and code, the component, the PFAS (CAS number, or total organic fluorine), its function and its range.
  5. Pay the $800 fee. It’s charged once per manufacturer, even when someone else files for you (Minn. R. 7026.0100).

For the first cycle, MPCA said it would accept the data collected to date, with your efforts to get supplier information documented. It hasn’t said how that applies to a report filed after the deadline, so document your requests either way.

After this, updates are due each February 1 when you add products, change them significantly or learn something new (Minn. R. 7026.0040). The rule also expects you to keep asking suppliers until the missing data is known (7026.0080).

If a retailer asks

Retailers ask because a store the state has notified can’t sell an unreported product. Tell them where you are, with dates, and don’t promise a date you can’t keep. Something like:

“We sell [products] in Minnesota. Our PFAS report under Minn. Stat. 116.943 is being prepared in PRISM, and we expect to submit it by [date]. We’ll send the submission confirmation as soon as it’s filed, and supplier declarations for the materials on request.”

Once it’s submitted, send the confirmation. If a product turns out to have no intentionally added PFAS, the signed supplier declarations are your answer.

What to keep on file

  • The PRISM submission confirmation and the fee receipt
  • Every supplier request, reminder, reply and non-reply, with dates
  • Signed declarations, safety data sheets and test reports
  • Any agreement with another company in your supply chain that reports for you (Minn. R. 7026.0020)
  • How you grouped products, and why

The rule asks you to document supplier communications, hand the records to MPCA on request, and keep them for five years after a product leaves the supply chain (Minn. R. 7026.0080).

How we help

A Minnesota late report is $1,250, plus the state’s $800 fee, which you pay directly. MPCA’s guide confirms consultants can file through PRISM’s Associations feature, so we file it for you. Start with a $250 Scope Check, credited if you go ahead within 30 days. See all prices.

Sources: Minn. Stat. 116.943, Minn. R. ch. 7026, Minn. Stat. 116.072, Minn. Stat. 115.071, MPCA PRISM guide. More in the Minnesota guide.

We file Minnesota late reports through PRISM for $1,250, plus the state’s $800 fee.

Ask about a late report ($1,250)