
Manufacturers and distributors around the country are gearing up to comply with Minnesota’s Amara’s Law, which targets the use of intentionally added perfluoroalkyl and polyfluoroalkyl substances (PFAS) in consumer products. The first stage of Amara’s Law took effect in 2025 when eleven categories of new products sold in Minnesota, such as carpets, cookware, dental floss, and menstrual products, were required to be made without PFAS. The goal of the law is to ultimately phase out all non-essential uses of PFAS due to their persistence in the environment and concerns with potential associated environmental and health risks.
As part of its initiative to drive transparency around PFAS use, Amara’s Law introduced several reporting requirements, which were outlined by the Minnesota Pollution Control Agency (MPCA) in December 2025. Compared to the federal PFAS reporting program administered by the Environmental Protection Agency (EPA) under the Toxic Substances Control Act (TSCA), Minnesota’s program is generally viewed as a stricter and more compliance-heavy program.
Scope and Applicability of Amara’s Law
Amara’s Law defines PFAS as a class of fluorinated organic chemicals that contain at least one fully fluorinated carbon atom. PFAS are considered “intentionally added” when their continued presence in a final product (or product component) is desired to perform a specific function.
Amara’s Law applies to products that 1) are manufactured after July 1, 2023, 2) are sold, offered for sale, or distributed in Minnesota, and 3) contain intentionally added PFAS. The law is channel-neutral, meaning it applies to any product that enters the Minnesota market, including products sold through direct sales, distribution channels, and online platforms. In response to public comments, the MPCA acknowledged that the phrase “offered for sale” may create uncertainty but clarified that the reporting requirement applies to all products made available for purchase in Minnesota, including those sold only online. The MPCA also advised manufacturers to rely on current and projected sales data to determine whether their products are anticipated to enter the Minnesota market. In essence, if a product is sold, offered, or shipped into Minnesota, the manufacturer must comply with the state’s PFAS reporting requirements.
Manufacturer Reporting Requirements Under Amara’s Law
Once a manufacturer determines that its product falls within the scope of Amara’s Law, the law requires submission of a report containing the following:
- A description of the product or product category;
- The purpose or function the PFAS serves in the product, including product components;
- The amount of each type of PFAS present in the product;
- The name and address of the manufacturer, along with a designated contact; and
- Any additional identifying information required by law.
Additionally, if the Commissioner has reason to believe that a product contains intentionally added PFAS that have not been disclosed, the Commissioner may require the manufacturer to test the product and report results within 30 days. Amara’s Law also imposes due diligence obligations on manufacturers. These include investigating their supply chains to obtain required PFAS information and retaining records of communications with suppliers for at least five years.
To reduce the burden of reporting requirements, the law allows (with Commissioner approval) for grouping of similar products and joint reporting by groups of manufacturers. Manufacturers may also report PFAS concentration ranges when precise quantities are unknown. Additionally, manufacturers may request waivers, extensions, or trade secret protections where applicable.
Extension, Waiver, and Exemption Requests
The MPCA has developed a form that manufacturers may use to request a 90-day extension for PFAS reporting. These extension requests are intended to be straightforward and do not require extensive documentation.
The MPCA has also made a waiver request form available for qualifying manufacturers that demonstrate that equivalent PFAS product information has already been made publicly available and is verifiable. All waiver and extension forms, along with their respective fees, must be postmarked by August 16, 2026.
Certain products are fully exempt from reporting under Amara’s Law. These include products already subject to federal PFAS regulations, products regulated under other Minnesota statutes, used products, and classified federal information.
Report Submission Process
All reports must be filed through the PFAS Reporting Information System for Manufacturers (PRISM) system. Each manufacturer must first register for an account, a process that may take at least two business days. Manufacturers are encouraged to register well in advance of applicable deadlines to avoid delays.
The PRISM system is optimized through the Chrome browser but is also accessible on Firefox and Safari. Within the system, manufacturers may either manually enter data or upload it using available import tools. PRISM provides several technical support resources in addition to their user and supplemental guides. For additional assistance, manufacturers may contact the MPCA at: pfasreporting.mpca@state.mn.us.
Key Deadlines for Manufacturer Compliance
- August 16, 2026: All extension and waiver requests must be submitted (postmarked).
- September 15, 2026: Initial deadline for reporting disclosures.
- December 14, 2026: Extended deadline for reporting disclosures (if an extension is granted).
- February 1 (annually thereafter): Annual updates are due, as applicable. Following a review period, all data, excluding trade secrets, will become publicly accessible.
- January 1, 2032: Ban on intentionally added PFAS in products, except for uses that are determined to be a currently unavoidable use.
- A currently unavoidable use is defined in the statute as “essential for health, safety, or the functioning of society and for which alternatives are not reasonably available.”
- A rulemaking process is underway to govern how the state determines currently unavoidable uses.
Manufacturers should note that failure to comply with Amara’s Law disclosure requirements constitutes a violation of Minnesota State Section 116.942 and may result in significant civil penalties. Squire Patton Boggs is available to assist with any questions regarding consumer product disclosure obligations and will continue to monitor developments related to PFAS disclosure requirements.






