New Mexico PFAS Reporting: What Is Due January 1, 2027
Founder & CEO Published Oct 22, 2026
New Mexico requires manufacturers to report intentionally added PFAS in products sold in the state by January 1, 2027. Reports go into New Mexico’s own system, NMPRS, not Minnesota’s PRISM. The scope is narrower than Minnesota’s: the state has said reporting covers consumer products, and it exempts medical devices, semiconductors, vehicles, and non-consumer electronics.
Who has to report?
The rule makes every manufacturer in the supply chain responsible for reporting, unless they agree in writing who reports. A trade group may file for its members, but each member must verify the data and pay the fee.
- Consumer products only. The New Mexico Environment Department (NMED) has said reporting applies to consumer products as the PFAS Protection Act defines them, not to industrial products. This was reported by Bergeson & Campbell in July 2026. Check whether your product is sold to consumers before you start.
- No size threshold. The rule has no small business exemption.
- Private labelers can count. NMED’s FAQ says a brand owner selling under its own label can be the manufacturer.
What is exempt?
The rule exempts these products from reporting:
- FDA-regulated medical devices, drugs, and their packaging
- Semiconductors
- Non-consumer electronics and laboratory equipment
- Motor vehicles, farm equipment, watercraft, and aircraft
- HVAC and refrigeration equipment that uses EPA-approved refrigerants
- Products used to generate, distribute, or store electricity
- Equipment used to make any of the exempt products
- Fluoropolymers that are solid at room temperature and pressure
- Veterinary products, registered pesticides, and public health or water testing products
- Used products and federally preempted products
Minnesota does not exempt medical devices or electronics from reporting. A product can be out of scope in New Mexico and still due in Minnesota.
What does each report need?
A report is required for each product or component with intentionally added PFAS. It must include:
- A product description with a UPC, SKU, or other numeric code
- The purpose of the PFAS
- Each PFAS by CAS number, as an exact concentration or a range
- Documentation verifying analytical method results
- The manufacturer’s name and address, and a contact’s name, address, and phone
New Mexico’s concentration ranges differ from Minnesota’s:
| New Mexico ranges (ppm) |
|---|
| Less than 100 |
| 100 to less than 500 |
| 500 to less than 1,000 |
| 1,000 to less than 5,000 |
| 5,000 to less than 10,000 |
| 10,000 or more |
You cannot copy Minnesota’s bands across. Ask suppliers for an exact concentration where you can, so one answer fits both states. The rule also has no “present but unknown” option, unlike Minnesota.
What are the deadlines and fees?
| Date | What is due |
|---|---|
| December 2, 2026 | Requests for a 90-day extension or a waiver for publicly available data |
| January 1, 2027 | Initial reports in NMPRS |
| Within 30 days of a significant change | Updated report |
| January 1, 2027 and 2028 | Bans on PFAS in listed product categories, such as cookware, cosmetics, and textiles |
| January 1, 2032 | Ban on all intentionally added PFAS, unless the use is currently unavoidable |
The initial report fee is $2,500. Each significant change update costs $1,000. The rule does not make clear whether the fee is per manufacturer or per report. Penalties reach $15,000 per violation.
A federal court blocked New Mexico’s PFAS labeling requirement in September 2026, and the state has appealed. The reporting deadline and the bans are not affected.
Can you reuse your Minnesota report?
Partly. The supplier data is the same kind: PFAS by CAS number, amount, and function, per component. But New Mexico uses a different system, different ranges, a different fee, and a different exemption list. It also asks for reporting of PFAS byproducts, which Minnesota does not.
The practical step is to collect one answer per part that works in both states:
- List the parts in products sold in each state. Remove the ones each state exempts.
- Ask each supplier by part number for the PFAS name, CAS number, exact concentration, and function. Use a PFAS supplier declaration.
- Map the answers into Minnesota’s bands for PRISM and New Mexico’s bands for NMPRS.
- Log every request and reply with dates.
For the Minnesota side, see Minnesota PFAS reporting: how to get the data from your suppliers.
TL;DR
When is New Mexico PFAS reporting due?
January 1, 2027, in NMPRS. Extension and waiver requests are due December 2, 2026.
Do medical device makers report in New Mexico?
No. FDA-regulated medical devices are exempt in New Mexico. They still report in Minnesota.
Do industrial products have to be reported?
NMED has said reporting covers consumer products, not industrial products. Confirm your product’s status with NMED if it is sold to both.
How much does it cost to report?
$2,500 for the initial report and $1,000 for each significant change update.
Sources
- 20.13.2 NMAC, as adopted April 2026. Exemptions, report contents, fees, penalties, and bans.
- NMED: PFAS information for manufacturers. NMPRS and deadlines.
- NMPRS FAQ. The reporting system.
- Bergeson & Campbell, July 30, 2026. Industrial products are out of scope.
- Beveridge & Diamond, September 2026. The labeling injunction.
- Verdant Law, October 2026. The state’s appeal.
Bridgecurrent asks your suppliers once for the PFAS data both states need, follows up until they answer, checks each reply, and keeps the dated record. See pricing.