Dual Delay: Minnesota Extends PFAS Products Reporting Deadline

After the U.S. Environmental Protection Agency (EPA) delayed the submission period for its one-time per- and polyfluoroalkyl substances (PFAS) reporting requirement under the Toxic Substances Control Act, Minnesota just extended its own (previously extended) PFAS products reporting deadline from July 1, 2026, to September 15, 2026. The Minnesota Pollution Control Agency cited challenges in collecting and submitting data under the state’s reporting rule, adopted in December 2025, as necessitating the delay. That rule requires manufacturers of intentionally added PFAS-containing products to submit a description of each product and the concentration and function of PFAS in it. Manufacturers unable to meet the new deadline may request a single, 90-day extension, which would extend reporting to December 2026. The Agency notes that 18 companies submitted reports ahead of the original deadline, data from which (except for protected trade secrets) is now publicly available. Given the fluidity of the rules and the deadlines, we continue to advise submitting closer to the (now later) end of the reporting period.