Read this before anything else
This is not legal advice and we are not your lawyer. You describe one named product line. We read the Minnesota PFAS-in-products reporting rule against the facts you sent and we write one of three verdicts: must file, need not file, or cannot tell from what you sent. The letter shows the tests, the sentences we used, and the pages we read.
A verdict is not a certificate that you are in the clear. We do not file the state report, we do not log into PRISM, we do not pay the state’s fee, and we will not write that you are in the clear. If the facts you sent were wrong, the verdict is wrong with them.
We do not test the product in a lab. This is a filer check, not a chemistry cutoff. Minnesota’s report, on the pages we saved, turns on PFAS that was added on purpose, not on every trace a lab might find.
Who this letter is forMPCA reporting page, fetched 25 Aug 2026
On the MPCA reporting page we saved on 25 Aug 2026:
| The test | The sentence we use | Where |
|---|---|---|
| Maker, brand owner, or (if those have no US presence) importer or first domestic distributor | "Manufacturer" means the person that creates or produces a product or whose brand name is affixed to the product. In the case of a product imported into the United States, manufacturer includes the importer or first domestic distributor of the product if the person that manufactured or assembled the product or whose brand name is affixed to the product does not have a presence in the United States. | Minn. Stat. § 116.943 subd. 1(o), compiled page fetched 25 Aug 2026 |
| The MPCA reporting FAQ says the same three roles in its own words | the entity that produces the product | MPCA reporting page, fetched 25 Aug 2026 |
| Sold, offered for sale, or distributed in Minnesota, including listings that sell only online | products sold only online | MPCA reporting page, fetched 25 Aug 2026 |
| The MPCA reporting FAQ treats leased or rented products as distributed in the state. The compiled rule 7026.0010 subp. 9, in the file we saved, defines “Distribute for sale” as shipping a product so a receiving party will sell it. We quote the FAQ for leases; we do not claim those words sit in subp. 9. | Products that are leased, rented, or otherwise distributed in the state are considered "distributed in the state" under Minnesota Rule 7026.0010, Subp. 9. | MPCA reporting page, fetched 25 Aug 2026 |
If you only put someone else’s branded goods on a shelf and you do not make, brand, or import them, say so on the form. That is often the whole question. You do not need to be based in Minnesota.
The dates that applypages fetched 25 Aug 2026
Today on the clock of the pages we saved is 25 Aug 2026. The first MPCA date had not passed then. The 16 Aug postmark cut-off had.
| What | Date | The sentence we use |
|---|---|---|
| Initial report, as the MPCA reporting page now administers it | 15 Sep 2026 | Initial reports are due by September 15, 2026. Products manufactured before July 1, 2023, are excluded. |
| Later date, only for manufacturers receiving an extension | 14 Dec 2026 | The reporting due date for manufacturers receiving an extension is Dec. 14, 2026. |
| Postmark cut-off for asking. As of 25 Aug 2026 that cut-off is past. Asking is not the same as receiving. | 16 Aug 2026 | The MPCA is processing a large volume of reporting due date extension requests following the Aug. 16, 2026, postmark deadline. |
| If the extension request is denied | 30 days after the denial notice, or 15 Sep 2026, whichever is later | The reporting due date for manufacturers denied an extension is 30 days after the notice of denial or Sept. 15, 2026, whichever is later. |
| Products manufactured before this date, excluded from reporting on the MPCA page and in the 2026 session law | 1 Jul 2023 | manufactured after July 1, 2023 |
| Updates, when required, after the first report | 1 Feb each year | Subsequent reports are due each year on February 1. |
| What the compiled statute page still prints for the first report. The session law did not change this date; it inserted the July 2023 manufacture cut-off. The MPCA pages name 15 Sep 2026. This letter uses the MPCA date. | 1 Jan 2026 | On or before January 1, 2026, a manufacturer of a product sold, offered for sale, or distributed in the state that contains intentionally added PFAS must submit to the commissioner information that includes: |
Do not write to us asking us to request your extension. That window is past on the dates above. A waiver is a different request and is not this letter.
The tests a verdict walks56 quotes re-checked
Each verdict names which of these held, with the fact you sent next to the sentence. If a fact the rule turns on is missing, we will not guess.
| The test | The sentence we use | Where |
|---|---|---|
| Intentionally added PFAS, not every lab trace | "Intentionally added" means PFAS deliberately added during the manufacture of a product where the continued presence of PFAS is desired in the final product or one of the product's components to perform a specific function. | Minn. Stat. § 116.943 subd. 1(l) |
| What Minnesota means by PFAS | "Perfluoroalkyl and polyfluoroalkyl substances" or "PFAS" means a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom. | Minn. Stat. § 116.943 subd. 1(q) |
| Used products | Products that have been previously installed, operated, or otherwise utilized by a prior owner are not required to be reported. | MPCA reporting page, fetched 25 Aug 2026 |
| Unused returns still in | This exemption does not apply to products returned to a retailer or offered for resale if they were not previously used. | MPCA reporting page, fetched 25 Aug 2026 |
| PFAS that arrives only as contamination in recycled content, on the MPCA FAQ | This product would not be reported because the PFAS would not be considered "intentionally added." | MPCA reporting page, fetched 25 Aug 2026 |
| A quiet supplier does not move the deadline | A one-time extension may be requested, but lack of supplier data does not remove the obligation to report. | MPCA reporting page, fetched 25 Aug 2026 |
| Internal or electronic-only PFAS: still in the 2026 report, even where the 2025 sales ban does not apply | Products that contain PFAS only in internal and electronic components are no longer subject to the 2025 sales prohibition but are subject to the 2026 PFAS reporting requirement. | MPCA reporting page, fetched 25 Aug 2026 |
The three verdicts
One of these three labels, in plain type, once.
- Must fileOn the facts you sent, you look like a manufacturer as the rule uses that word, the product is sold, offered, or distributed in Minnesota, PFAS was added on purpose, and none of the exclusions you described apply. The letter does not file the report, fill the state form, or pay the state fee.
- Need not fileOn the facts you sent, at least one test does not hold: you are not the maker, brand owner, or importer the rule names; or the product was made before 1 Jul 2023; or it is a used product the MPCA FAQ leaves out; or you state that PFAS was not added on purpose. The letter names the test that failed and quotes the source. It is not a permission slip you can show a retailer or the agency.
- Cannot tell from what you sentA fact the rule turns on is missing or in conflict. We will not pick a side to make the letter feel finished. A silent supplier is not “need not file.” A write-in of “foam,” “food packaging,” or “we are FDA” is cannot tell until a person matches the product to the compiled definitions. See the 325F.072 / 325F.075 section below.
What we need from youemail, not a web form
There is no form on this page and nowhere to upload a file. You email the answers. A person reads them. How you pay is an email thread until a checkout link is minted; this page has no pay button yet.
| What we ask | Why |
|---|---|
| Legal company name | Who is asking |
| Brand on the product, if different | The rule may treat a brand owner as a manufacturer |
| Named product line | The unit we price and the unit we verdict |
| Short description of what it is | So the letter is about a real thing, not a SKU code |
| Your role: we make it / our brand is on it / we import it into the US / we only retail someone else's brand / other | Manufacturer test |
| Sold, offered, or distributed in Minnesota? Yes / no / only online / we do not know. Include leased or rented if that is how it goes out. | Minnesota nexus |
| When was this product line manufactured? Before 1 Jul 2023 / on or after 1 Jul 2023 / mixed dates / we do not know | Older-product cut-off |
| Was PFAS added on purpose to the product or a part of it? Yes / no / supplier will not say / we have not asked / we do not know | Intentionally added |
| If yes: what job does the PFAS do? | Function is part of the state’s report; collected so the letter can say whether you already have what a filing would need |
| Is this a used product? Yes / no / returned unused to a retailer / we do not know | Used-product exclusion |
| Pesticide, fertilizer, soil or plant amendment, or liming material? Yes / no / we do not know | May be a different agency’s form; default verdict is cannot tell on that split |
| Has another company in the chain told you in writing that they already filed? Yes (attach) / no / we do not know | Not need-not-file on its own. One party may file for others only with a documented agreement. |
| Did you postmark an extension request by 16 Aug 2026? Yes / no / we do not know | Which calendar date applies |
| Anything else you want on the letter (part numbers, UPC, supplier name) | Optional. We will not hunt a supplier for you. |
A worked example, on facts we made upinvented company, real quotes
Every word of the company and product below is invented. Nobody sent this. The quotes next to the tests are real, from the pages we saved on 25 Aug 2026.
| Field | What they sent |
|---|---|
| Legal company name | NORTHWOOD COATINGS LLC |
| Brand | NORTHWOOD |
| Named product line | NWC-400 WATER-SHED FABRIC FINISH |
| What it is | A water-resistant finish for outdoor fabric, sold in 5 litre jugs. |
| Role | we make it |
| Minnesota | yes, including online listings that ship into the state |
| Manufactured | on or after 1 July 2023 |
| PFAS added on purpose | yes, added on purpose for water resistance |
| Used product | no |
| Verdict on those facts | must file |
On those facts the manufacturer test holds, Minnesota nexus holds, the product was made after 1 Jul 2023, PFAS was added on purpose, and it is not a used product. The letter would still not file the report, and it would still not say they are in the clear.
What 325F.072 and 325F.075 actually covercompiled texts fetched 25 Aug 2026
Minn. Stat. § 116.943, subdivision 8(a)(2), in the compiled page we saved, says that section (the PFAS-in-products reporting section) does not apply to:
a product regulated under section 325F.072 or 325F.075; or
The compiled texts of those two sections, as we saved them, are not themselves a 116.943 reporting-deadline statute. We will not treat a write-in of “foam” or “food packaging” as a finished need not file answer from those two sections alone. That ground is cannot tell until a person matches the product to the compiled definitions.
| What 325F.072 actually says | The compiled words | Where |
|---|---|---|
| Title of the compiled section | 325F.072 FIREFIGHTING FOAM. | Minn. Stat. § 325F.072 |
| What “class B firefighting foam” means in that section | "Class B firefighting foam" means foam designed to prevent or extinguish a fire in flammable liquids, combustible liquids, petroleum greases, tars, oils, oil-based paints, solvents, lacquers, alcohols, and flammable gases. | 325F.072 subd. 1(b) |
| The prohibition, as compiled | No person, political subdivision, or state agency shall manufacture or knowingly sell, offer for sale, distribute for sale, or distribute for use in this state, and no person shall use in this state, class B firefighting foam containing PFAS chemicals. | 325F.072 subd. 3(a) |
| A 24-hour notification, to the Minnesota Fire Incident Reporting System, on discharge, use, or release of class B foam with intentionally added PFAS. The words file / filing do not appear in the compiled section we saved. | Beginning on July 1, 2020, any person, political subdivision, or state agency that discharges, uses, releases, or knows of a discharge, use, or release of class B firefighting foam that contains intentionally added PFAS chemicals must be reported to the Minnesota Fire Incident Reporting System within 24 hours of the discharge, use, or release. | 325F.072 subd. 2 |
| What 325F.075 actually says | The compiled words | Where |
|---|---|---|
| Title of the compiled section | 325F.075 FOOD PACKAGING; PFAS. | Minn. Stat. § 325F.075 |
| What “food package” means, opening sentence. The compiled definition also names shipping containers, unsealed cups and plates, coatings, inks, and labels. | "Food package" means a container applied to or providing a means to market, protect, handle, deliver, serve, contain, or store a food or beverage. | 325F.075 subd. 1(b) |
| The prohibition, as compiled | No person shall manufacture or knowingly sell, offer for sale, distribute for sale, distribute, or offer for use in Minnesota a food package that contains intentionally added PFAS. | 325F.075 subd. 2 |
| The compiled section has no matching line for report / notification / file / filing. It does tell a person to furnish information when the Pollution Control Agency commissioner asks. | When requested by the commissioner of the Pollution Control Agency, a person must furnish to the commissioner any information that the person may have or may reasonably obtain that is relevant to show compliance with this section. | 325F.075 subd. 3(b) |
Medical devices: compiled 116.943 subd. 8(b) carves prosthetic and FDA medical products out of subdivisions 4 and 5 (testing and bans), not obviously out of subdivision 2 (reporting). The MPCA prohibitions page we saved says those products must still be reported if they contain intentionally added PFAS. We do not advertise a medical-device out. A write-in of “we are FDA” is cannot tell.
However, those products must be reported if they contain intentionally added PFAS starting in 2026. (Minn. Stat. § 116.943, Subd. 8)
What this is not
- Not legal advice.We are not your lawyer.
- Not a filing.We do not submit the state’s report and we do not log into PRISM. The MPCA reporting page names PRISM as the system manufacturers use to submit reports and pay related fees.
- Not a lab.We do not test for PFAS.
- Not a certificate that you are in the clear.That sentence will not appear on the letter or this page.
- Not the 2025 category sales bans, and not the 2032 currently-unavoidable-use ban.Those are different duties. This letter is the reporting check.
- Not the state’s one-time $800 filing fee.The MPCA reporting page says each manufacturer pays that fee inside PRISM. We do not collect it and we do not pay it for you. Our fee is $450 for the first named product line.
- Not a waiver request, not an extension request, not a trade-secret filing.The 16 Aug 2026 postmark window is past on the pages we saved.
Questions we are actually asked
What is PFAS, in one paragraph? Minnesota’s definition, on the compiled statute page we saved, is a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom. That is broader than a short lab list of famous names. This letter does not test your product for them.
What if you are wrong? The letter shows its reasoning and its sources. It is a reading of the rule, not legal advice. If a page we cited later changes, the letter still means what it meant on its date. If the facts you sent were wrong, the verdict is wrong with them. If we misread a page we already cited, we send a corrected letter for that product line; whether that correction is free is not a live promise on this page.
Do you file the report? Do you tell us we are in the clear? No and no.
What if we do not know whether PFAS is in the product? That is cannot tell, unless some other test already knocks the product out. We will not treat a silent supplier as need not file.
We did not ask for the 16 Aug extension. What date applies? 15 Sep 2026, on the MPCA reporting page we saved. The 14 Dec 2026 date is for manufacturers receiving an extension. A request is not an approval.
We have twenty product lines. Is that twenty times the first-line price? No. The first named product line on one request is the catalog price on this page. Each further named product line on the same request is priced in the written terms below the email path, not in the rail. Grouping similar products into one “line” is your call on the form. The state’s own grouping rules for PRISM are a different question and are not this letter.
Can we use this letter as a certificate for a retailer or the agency? No.
Where the words came from25 Aug 2026
Every quoted sentence above was searched for, after folding spaces and punctuation, in the saved file named next to it. All 56 allowed quotes were found on this build. One mismatch and this page does not build.
| Saved page | File on this disk |
|---|---|
| MPCA reporting page, fetched 25 Aug 2026 | reporting-pfas-in-products.extracted.txt |
| MPCA prohibitions-and-reporting page, fetched 25 Aug 2026 | pfas-use-prohibitions-and-reporting.extracted.txt |
| MPCA reporting-and-fees rulemaking page, fetched 25 Aug 2026 | pfas-in-products-reporting-and-fees.extracted.txt |
| compiled Minn. Stat. § 116.943, fetched 25 Aug 2026 | stat-116.943.extracted.txt |
| 2026 Minn. Laws ch. 127 art. 14 § 4, fetched 25 Aug 2026 | laws-2026-c127-art14-s4.section4.html |
| compiled Minn. R. ch. 7026, fetched 25 Aug 2026 | rules-7026-full.extracted.txt |
| compiled Minn. Stat. § 325F.072, fetched 25 Aug 2026 | 325F.072.txt |
| compiled Minn. Stat. § 325F.075, fetched 25 Aug 2026 | 325F.075.txt |
The compiled statute page still banners that subd. 2 has been amended by 2026 Chapter 127, Article 14, Section 4, and still prints the old 1 Jan 2026 due date. The session-law text inserts “manufactured after July 1, 2023”. When the compiled page will show those words is unverified.
Ask before you pay
No pay button on this one yet. Email operations@ustechautomations.com. Name the product line. We reply with the form fields we need and the checkout link, before you spend anything.
What you would be paying for: $450 once, for the first named product line on one request. Each further named product line on the same request is $175 once. Nothing recurring, nothing to cancel and no subscription behind it. This is our fee for the letter. It is not the state's one-time $800 filing fee, which we do not collect and do not pay for you. After you pay, a person emails you the dated letter for that named product line within one working day of your payment. The letter is a reading of the reporting rule against the facts you sent. It is not legal advice, not a filing, and not a certificate that you are in the clear.
Email us the product lineSay the named product line and your role (maker, brand owner, importer, or retailer). We will tell you what we need on the form before you pay. There is no pay button on this page yet.