On December 8, 2025, the Minnesota Pollution Control Agency (MPCA) finalized its PFAS-in-Products program rules in response to an Administrative Law Judge order requiring the Agency to reduce fees, among other changes. Under the rule, manufacturers must submit PFAS information – including product descriptions, PFAS type, quantity, function and manufacturer details – to MPCA by July 2026, and pay a fee to support the program.
After Administrative Law Judges Timothy O’Malley and Jim Mortenson disapproved the rule in August 2025 for exceeding the scope of the State’s authorizing PFAS-in-Products law, MPCA revised it to reduce the reporting fee from $1,000 to $800, eliminate the annual recertification requirement (to verify previously submitted, even if unchanged, information) and its associated fee, and to remove the option for manufacturers to voluntarily update reports when PFAS is reduced or eliminated from a product.
MPCA also addressed how these rules interact with federal PFAS reporting under EPA’s Toxic Substances Control Act in a separate letter to Interim Chief Judge O’Malley. The letter asserts that any cumulative effect of the two reporting and fees rule will be minimal as Minnesota’s rules more broadly cover current and future PFAS uses, apply a stricter due diligence standard and define PFAS more expansively.
Finally, MPCA announced that its PFAS Reporting Information System for Manufacturers (PRISM), which will publish non-confidential reported data, will begin a limited rollout in December 2025, with full access for all manufacturers in January 2026. We will continue to monitor and update as developments unfold – stay tuned to this space.