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ARTICLE · 19 DECEMBER 2025

Minnesota Finalizes Jan. 1, 2026, PFAS Reporting Requirement, Impacting Manufacturers Of Complex Products

Van Ness Feldman LLP
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The Minnesota Pollution Control Agency (MPCA) adopted on December 8, 2025, a final rule regarding the reporting of per- and polyfluoroalkyl substances (PFAS) in products, which is set to impose significant...

United StatesEnvironment
Britt Fleming
Britt Fleming
Dana J. Stotsky
Dana J. Stotsky
Benjamin W. Schultz
Benjamin W. Schultz

The Minnesota Pollution Control Agency (MPCA) adopted on December 8, 2025, a final rule regarding the reporting of per- and polyfluoroalkyl substances (PFAS) in products,1 which is set to impose significant new compliance obligations on manufacturers. This rule, codified under Chapter 7026 of Minnesota Rules, establishes reporting requirements and associated fees for products that are sold, offered for sale, or distributed in the state. The rule applies broadly to any product that contains intentionally added PFAS and its constituent components. Whereas the federal PFAS Reporting Rule is currently being revised to lessen burdens on industry, Minnesota is charging forward with what are objectively highly burdensome reporting requirements.

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