Minnesota PFAS Reporting: How to Get the Data From Your Suppliers

Minnesota requires every manufacturer of a product sold in the state to report intentionally added PFAS in that product and in each of its components. The hard part is not the filing. It is getting the data from suppliers, many of whom have never been asked about PFAS. The rule says you keep asking until the data is known, and that you keep the records for five years.

Most filers are not there yet. On October 16, 2026, more than half of the PFAS rows published in Minnesota’s reporting system listed the amount as unknown.

Who has to report?

The statute defines the manufacturer as the company that makes the product or whose brand is on it. An importer or first distributor reports only when the maker and brand owner have no US presence.

• Contract manufacturers generally report too. MPCA tried to shift the duty to brand owners in its rule, and the judge struck that part. Each manufacturer reports unless the two sign a written agreement that one reports for the other.
• There is no size threshold. There is no small business exemption and no de minimis level.
• Medical devices must report. FDA regulated devices are exempt from the bans, not from reporting.
• Some products are out of scope. These include products made before July 1, 2023, federally preempted products, and used products.

What does each report need?

Reports cover each product or component with intentionally added PFAS. For each component you give:

1. The PFAS by name and CAS number
2. Its concentration range
3. The function it serves

Parts sold for use in making other products count as products too. A one-page “PFAS free” letter that does not name parts will not fill these fields.

What are the deadlines?

Date	What is due
September 15, 2026	Initial reports
December 14, 2026	Reports from manufacturers granted a 90 day extension. MPCA granted over 1,000
February 1, every year	Updates to your report
January 1, 2032	Broad ban on intentionally added PFAS, unless MPCA finds the use currently unavoidable

The fee is a one-time $800 per manufacturer. Updates are free.

How much supplier data does the rule require?

Minnesota Rule 7026.0080 has no “reasonably ascertainable” standard. You must keep requesting data from your supply chain until all required information is known, using more than one method if needed, and keep the records for five years.

• You can file unknowns. The report accepts “present but unknown” values, which you then update.
• The first cycle is lenient. MPCA said a timely report with all available data and due diligence records counts as compliant for this round.
• Supplier refusal is generally not a defense. Expect a stricter standard for the February updates.
• Email counts. MPCA’s FAQ lists email as an outreach method and accepts an email system such as Outlook as the record.

Why is supplier data so hard to get?

Response rates in the public comment record are low.

• Daikin Applied contacted its 225 main suppliers monthly about its top parts and saw a 39.7% response rate over eight months.
• The Coalition of Manufacturers of Complex Products put the average response to repeated chemical inquiries at about 30%.
• The Association of Equipment Manufacturers estimated 60 months to get data from 80% of a supply chain.

Small and custom suppliers are the slowest. Machine shops, molders, platers, and cable shops publish nothing about PFAS, and many have never been asked.

How do you collect it?

1. Scope the list. Start with the parts in products sold in Minnesota, then the direct suppliers of those parts. Most mid-size manufacturers chase direct material and component suppliers, not every vendor.
2. Find the right person. A sales inbox rarely answers a chemical question. Find someone at each supplier who can speak for its parts.
3. Ask by part number. List the supplier’s part numbers and ask, for each one, whether PFAS is intentionally added, and if so the name, CAS number, concentration range, and function. Accept IPC-1752A, a spreadsheet, or a signed letter that names the parts.
4. Follow up on a schedule. When a contact goes quiet or forwards the request, find a better placed person at that supplier and ask again.
5. Check every answer. Part numbers must match. CAS numbers must be valid. Ranges must fit Minnesota’s bands. Send back anything vague.
6. Log everything. Every request, reminder, and reply, with dates. That log is your due diligence record.
7. Plan the February 1 update. Every unknown you filed becomes next year’s chase list, along with new and changed parts.

TL;DR

Does Minnesota PFAS reporting apply to small manufacturers?

Yes. There is no size threshold. If you make or brand a product sold in Minnesota, you report.

Do contract manufacturers have to report?

Generally yes, unless a written agreement says the brand owner reports for you.

Can I report PFAS as unknown?

Yes. You can file “present but unknown,” but you must keep asking suppliers and update the report.

When is the next deadline?

December 14, 2026 for manufacturers with an extension. February 1 every year for updates.

Sources

1. Minn. Stat. 116.943. The statute, including the manufacturer definition.
2. Minn. Rules chapter 7026. Report contents (7026.0020) and supplier data and records (7026.0080).
3. MPCA: Reporting PFAS in products. Deadlines, extensions, fee, and FAQ.
4. MPCA: PFAS use prohibitions and reporting. Medical devices and bans.
5. MPCA: Currently unavoidable use. The 2032 process.
6. MPCA response to comments, June 2025. Daikin Applied’s response rate.
7. MPCA 2023 comment file. AEM and the Coalition of Manufacturers of Complex Products.
8. Bergeson & Campbell on the 2026 amendment. The July 1, 2023 cutoff.
9. PRISM public search. Published reports, checked October 16, 2026.

Bridgecurrent sends PFAS requests from your own email, follows up until suppliers answer, checks each reply, keeps the dated record, and prepares your PRISM filing. See pricing.