Minnesota's PFAS reporting rule - established in 2023 under
Amara's Law - is widely considered the most stringent in the United States and will create significant compliance challenges for recreational boat builders and marine manufacturers, many of which are small businesses.
The law establishes expansive reporting requirements for products containing intentionally added PFAS, impacting not only Minnesota-based manufacturers but any company selling into the state. NMMA has been actively engaging with state officials to address the rule's practical implications, particularly given the complexity of global, multi-tiered marine supply chains and the lack of viable PFAS-free alternatives for many safety-critical components.
Now, beginning September 15, 2026, manufacturers of products sold or distributed in Minnesota that contain intentionally added PFAS will be required to submit detailed reports through the
PFAS Reporting and Information System for Manufacturers (PRISM) to the Minnesota Pollution Control Agency (MPCA), along with an associated fee.
The reporting requirement calls for detailed chemical data at the component level-including items such as gaskets, seals, wiring, and other subassemblies-creating significant compliance challenges for manufacturers. Required information includes:
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A brief description of the product or category;
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PFAS chemicals used in the product or its components;
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The concentration of PFAS chemicals in a product or components of a product made up of homogeneous material;
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The function that each PFAS chemical provides to the product or its components;
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Manufacturer information;
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Contact information for the authorized representative of the manufacturer who has the authority to execute or direct others to execute reporting to the state;
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An alternative to the authorized representative.
Shown below is an excerpt from the public PFAS PRISM database showing the level of detail required for a biometric code reader product from HID corporation. Each individual PFAS chemistry is listed as a separate line item. All information submitted to the database is publically accessible, thus there may be concern about proprietary data.
Image: Example of reporting data from the PFAS PRISM reporting database.
MPCA has not addressed the marine industry's request for critical exemptions or offered solutions to the complex reporting challenges faced by boat manufacturers. NMMA continues to advocate for a more practical, marine-specific compliance approach that reflects the complexity of recreational boats and their supply chains. For questions regarding PFAS, please reach out to Jeff Wasil, NMMA's Vice President, Environmental Compliance & Marine Technology, at
[email protected].