Minnesota PFAS February 1 Update: What You Must Report Each Year

Filing your first Minnesota PFAS report did not end the obligation. By February 1 of each year, you must update your PRISM report if anything changed in the prior calendar year. For most filers, the biggest change is new supplier data on the parts they reported as unknown. The first update is due February 1, 2027.

When do you have to file a February 1 update?

Minnesota Rule 7026.0040 requires an update by February 1 if, in the prior calendar year, any of these happened:

1. A significant change. A new PFAS not reported before, or a change that moves a concentration into a different range.
2. New information. You received information that changes what you reported, for example a supplier answered a question you had filed as unknown.
3. A new product. You began selling a product with intentionally added PFAS in Minnesota. Products first sold after January 1, 2026 are reported by February 1 of the following year.

If none of these happened, there is nothing to update. There is no fee for updates. The $800 fee is paid once per manufacturer.

What counts as a significant change?

The rule defines it narrowly:

• A PFAS appears in a product or component that you had not reported before.
• A PFAS concentration moves into a different range, for example from “100 to less than 1,000 ppm” into “1,000 to less than 10,000 ppm”.

A supplier switch, a redesigned part, or a new resin grade can cause either one. Ask suppliers about changed parts, not just new ones.

What about the unknowns you filed?

PRISM let you file “present but unknown” for the PFAS, its amount, or its function. Many filers did. On October 16, 2026, more than half of the PFAS rows published in PRISM listed the amount as unknown.

An unknown is not a final answer. Minnesota Rule 7026.0080 requires you to keep asking your supply chain until all required information is known. When a supplier answers, that is new information, and it belongs in your next February 1 update.

Will MPCA be stricter on February 1?

For the first cycle, MPCA said a timely report with all available data and records of due diligence would count as compliant. Expect less patience in the updates. Trade association summaries of MPCA guidance warn that a simple claim of supplier refusal is generally not acceptable. MPCA has not published a detailed standard for the 2027 update.

Assume your due diligence file will be read. It should show who you asked, when, by what method, what they said, and what you did when they did not answer.

How do you prepare the February 1 update?

1. Pull your unknowns. Export every PRISM row with an unknown PFAS, amount, or function. Each one maps to a supplier and a part.
2. Add new and changed parts. List parts in products sold in Minnesota that are new since your report or have changed suppliers, materials, or drawings.
3. Find the right person at each supplier. If your first request went unanswered, the contact was probably wrong. Find a quality or compliance contact who can speak for the parts.
4. Ask by part number. Send each supplier a pre-filled PFAS supplier declaration listing only its parts.
5. Follow up on a schedule. Use more than one method or contact if the first one fails. Log every attempt with its date.
6. Check each answer. Part numbers must match, CAS numbers must be valid, and ranges must fit Minnesota’s bands.
7. Update PRISM by February 1. Change the rows that have new data, add new products, and keep the rest as filed.

Start early. Public comments on the rule put supplier response rates at about 30% to 40%, even with monthly follow-up. Suppliers also get busy in December.

TL;DR

When is the Minnesota PFAS update due?

February 1 every year, starting February 1, 2027, if anything changed in the prior calendar year.

Is there a fee for the February 1 update?

No. The only fee is the one-time $800 per manufacturer.

Do I have to update unknowns?

Yes, once you learn the answer. You must keep asking suppliers until the data is known.

What if nothing changed?

Then no update is required. Keep your due diligence records anyway. They must be kept for five years.

Sources

1. Minn. Rules 7026.0040. Annual updates.
2. Minn. Rules 7026.0010. Definition of significant change.
3. Minn. Rules 7026.0080. Supply chain requests and records.
4. Minn. Rules 7026.0100. Fees.
5. MPCA: Reporting PFAS in products. Deadlines and FAQ.
6. MPCA supplemental PRISM guide, March 2026. Unknowns and updates.
7. RVIA on MPCA’s reaffirmed deadline, June 2026. Supplier refusal guidance.
8. PRISM public search. Published reports, checked October 16, 2026.

Bridgecurrent chases your open unknowns and new parts before February 1, checks each supplier reply, keeps the dated record, and prepares your PRISM update. See pricing.