ARTICLE
9 September 2026

Minnesota’s September 15, 2026, PFAS Reporting Deadline Is Fast Approaching

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Bergeson & Campbell

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Bergeson & Campbell, P.C. is a Washington D.C. law firm focusing on chemical product approval and regulation, product defense, and associated business issues. The Acta Group, B&C's scientific and regulatory consulting affiliate provides strategic, comprehensive support for global chemical registration, regulation, and sustained compliance. Together, we help companies that make and use chemicals commercialize their products, maintain compliance, and gain competitive advantage as they market their products globally.
Minnesota manufacturers face a critical September 15, 2026 deadline to report products containing intentionally added PFAS substances, with recent legislative amendments exempting products manufactured before July 1, 2023. The Minnesota Pollution Control Agency has processed over 17,000 product reports through its PRISM system and provides guidance for companies navigating the reporting requirements and fee payment process.
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As we discussed in our recent podcast episode, manufacturers of products sold, offered for sale, or distributed for sale in Minnesota must submit a report by September 15, 2026, that includes information about each product or component that contains intentionally added per- and polyfluoroalkyl substances (PFAS). The Minnesota legislature amended the statute in May 2026 to exclude products manufactured before July 1, 2023, from the reporting requirements. This date exemption applies to the manufacture date of the final product, not components within the product. The Minnesota Pollution Control Agency’s (MPCA) August 28, 2026, Daily Digest Bulletin includes tips for companies that have not yet reported, suggesting that companies begin creating accounts by following the instructions in the PFAS reporting guide and how-to videos. The supplemental guide to the PFAS Reporting and Information System for Manufacturers (PRISM) explains certain reporting scenarios, such as reporting in groups, reporting custom products, and how to handle incomplete information from the supply chain. According to MPCA, “PRISM is performing well. Reports on over 17,000 products have already been submitted, reviewed, and published. Thousands more are pending review.” MPCA states that product reports submitted with a fee payment by 11:59 p.m. (CDT) on September 15, 2026, will meet the reporting deadline. While payment for the fee for extension requests needed to be made by check, PRISM will prompt reporters for a credit card. MPCA notes that it will not publish reports in the public search of PRISM until after its review.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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