Minnesota is taking action to limit the use of per- and polyfluoroalkyl substances (PFAS) in consumer products to protect human health and the environment. PFAS have been widely incorporated into consumer products for decades due to their nonstick, water-repellent, heat-resistant, and grease-resistant properties. However, these synthetic chemicals pose environmental and public health risks because they do not naturally degrade, earning the designation "forever chemicals."
Learn more about PFAS and how they impact regulations on our blog.
Minnesota’s PFAS ban, known as Amara’s Law, has a phased implementation approach structured around several key enforcement deadlines:
These deadlines emphasize the importance of early compliance planning for manufacturers, importers, and distributors.
The definition of a “product” under Amara's Law includes the following distinctions:
The first PFAS prohibitions under Amara’s Law include intentionally added PFAS in the following 11 product categories:
Products in these categories are subject to Minnesota’s PFAS regulation if they contain intentionally added PFAS. PFAS are designated as “intentionally added” if the chemicals are deliberately used during manufacturing to serve a specific function, such as water resistance or chemical stability. However, incidental contamination, such as trace PFAS introduced through water or other environmental sources, is not considered intentional.
Amara’s Law applies to a variety of consumer goods, with specific guidance on how the law impacts furniture, cookware, cleaning products, and more. The following categories outline how regulated products are defined, as well as specific inclusions or exemptions under the current framework. Products in these categories must be manufactured without PFAS beginning in 2025.
Juvenile products are defined here as products aimed at children under 12 years old. Minnesota’s PFAS law applies broadly to the following categories of juvenile products, including but not limited to:
Notable exceptions to this law include:
The law covers both movable furniture and textile furnishings, including items that are:
This definition encompasses patio cushions (if not permanently affixed), as well as movable and cushioned industrial seating.
However, vehicle and transit seating are exempt until 2032, when broader prohibitions will apply unless the use is deemed “currently unavoidable.”
The law covers products with non-stick PFAS coatings on food-contact surfaces. This includes:
Even broader appliances, such as toasters and refrigerators, may be regulated if their interior surfaces or refrigerants contain PFAS. If the cookware product has PFAS in internal components, it will be subject to the 2032 prohibition. Manufacturers of such products must carefully assess component materials to ensure compliance.
The Minnesota PFAS regulation extends beyond the traditional cleaning chemicals like:
To also include:
However, products used exclusively in industrial manufacturing processes—such as large-scale production chemicals—are exempt until 2032 unless designated to be currently unavoidable uses. This distinction underscores the state’s focus on consumer exposure pathways in the initial phase of implementation.
Companies must ensure that, as of January 1, 2025, they do not sell or distribute prohibited products in Minnesota. This requirement is not limited by geography and applies to:
However, leasing a product is not considered a sale under the statute, and is therefore not currently prohibited.
To meet compliance expectations, companies should maintain robust documentation, including:
While third-party certification is not required, it is strongly recommended as best practice. Minnesota has not yet specified a document retention period, but long-term recordkeeping is advisable in case of future enforcement or dispute resolution.
Beginning in 2026, reporting obligations will be phased in. The responsibility falls on manufacturers if their products remain on the market. They will be required to disclose the presence of intentionally added PFAS, even if the product is not newly introduced. This includes:
Used product sales are exempt from PFAS restrictions; however, bundled products that include prohibited components remain subject to the ban. Importers are responsible for ensuring compliance and must exercise due diligence by auditing their upstream suppliers to verify the absence of intentionally added PFAS. There is no automatic sell-through allowance for inventory manufactured or imported prior to 2025, meaning that even existing stock must meet current PFAS restrictions in order to be sold. Additionally, the regulations include clarifications on the following specific product categories:
Minnesota’s PFAS regulation framework prioritizes education and compliance support, but also includes enforcement mechanisms for non-compliance. The Minnesota Pollution Control Agency (MPCA) has the authority to direct manufacturers to test products for PFAS and request supporting documentation from manufacturers to verify PFAS-related claims. Testing may include total organic fluorine analysis as a screening method and targeted testing for specific PFAS compounds. A threshold of 100 parts per million (ppm) may be used to indicate potential intentional use, but it is not a legal limit—rather, it serves as a trigger for further investigation.
Currently, the MPCA does not require the use of specific testing methods, such as EPA Method 1633, allowing manufacturers flexibility in their analytical approaches. Manufacturers may challenge MPCA findings by submitting their own test results or data, with disputes resolved on a case-by-case basis. This approach aims to balance regulatory enforcement with scientific flexibility and due process.
Recordkeeping, documentation, and a multitude of regulatory deadlines put unnecessary strain on companies. A proactive approach to compliance is the best way to stay ahead of obligations and ensure your company’s safety amidst supply chain turbulence. Source Intelligence’s PFAS solution offers a streamlined way to maintain supply chain visibility with complete compliance software.
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