Minnesota PFAS Restrictions — Amara's Law

By the Opora Editorial Team

There is a particular irony embedded in Minnesota's PFAS regulatory story. 3M — the company that invented PFOA and PFOS, manufactured them at its Cottage Grove and Decatur plants for decades, and paid a $10.3 billion settlement in 2023 to address contamination of public water systems — is headquartered in Maplewood, Minnesota. The state that hosted that industrial legacy is now home to the strictest PFAS-in-products law in the United States outside of Maine. Amara's Law, enacted as part of the One Minnesota Budget (HF 2310, signed May 24, 2023) and codified at Minn. Stat. § 116.943, bans PFAS in 11 product categories — including cleaning products — as of January 1, 2025. For commercial cleaning operators distributing floor waxes, degreasers, and fabric-maintenance products in Minnesota, that date is not a future planning horizon: it is a compliance obligation that arrived over a year ago.

The 3M Legacy and the Regulatory Response

3M announced in December 2022 that it would exit all PFAS manufacturing by the end of 2025. Its $10.3 billion settlement with U.S. municipalities over drinking-water contamination — announced June 22, 2023, weeks after Amara's Law was signed — underscored why Minnesota legislators moved so decisively. The settlement drew on research by the Minnesota Pollution Control Agency (MPCA) documenting PFAS contamination in the Twin Cities East Metro, where 3M's Cottage Grove operations contaminated municipal wells serving Washington County communities. MPCA's East Metro 3M PFAS contamination page remains one of the most detailed state-level PFAS investigations in the country. The law's namesake — Amara — was a child whose family lived near contaminated East Metro wells, reflecting a political commitment that cleaning vendors must understand when anticipating how enforcement will be prioritized.

What Amara's Law Bans Immediately: The 2025 Prohibitions

Under Minn. Stat. § 116.943, subd. 3(a), effective January 1, 2025, a person may not sell, offer for sale, or distribute for sale in Minnesota any product in the following 11 categories if it contains intentionally added PFAS: (1) carpets or rugs, (2) cleaning products, (3) cookware, (4) cosmetics, (5) dental floss, (6) fabric treatments, (7) juvenile products, (8) menstruation products, (9) textile furnishings, (10) ski wax, and (11) upholstered furniture.

Unlike Maine (which granted CUU exemptions before its 2026 ban) and Illinois (which stages bans over a decade), Minnesota's 2025 prohibitions came with no currently-unavoidable-use safety valve. Minn. Stat. § 116.943 explicitly states that "currently unavoidable use" determinations do not apply to 2025-prohibited products. There is no grace period, no extension process, and no small-business waiver for these 11 categories. The prohibition also extends to packaging used with prohibited products.

Floor Waxes, Floor Finishes, and Cleaning Products: Commercial Impact

The MPCA's published guidance on the 2025 prohibitions states explicitly: "The definition of cleaning products includes 'a polish or floor maintenance product.' Therefore, floor waxes and other floor finishes containing intentionally added PFAS are considered cleaning products and will be prohibited from sale and distribution in 2025." This single sentence eliminates an entire category of products that janitorial distribution houses have relied on for decades — PFAS-based leveling agents in floor finishes improve gloss, durability, and burnishing response in ways that non-fluorinated polymers have only recently matched. See the MPCA 2025 PFAS prohibitions guidance for the full scope of the prohibition.

The 2025 prohibition applies to products used primarily for domestic, commercial, or institutional cleaning purposes. It does not apply to products used for cleaning within an industrial manufacturing process — a carve-out recognizing the distinction between consumer-accessible cleaning products and in-process industrial cleaning chemicals. However, this exemption is narrow: a janitor cleaning the floors of a Minnesota factory using a PFAS-containing floor finish is distributing a prohibited cleaning product even if the facility hosts manufacturing operations. Carpet and floor-covering prohibitions under the same 2025 wave cover any fabric containing intentionally added PFAS marketed or intended for use as a floor covering, including car floor mats, recreational vehicle carpeting, outdoor rugs, and synthetic turf (Minn. Stat. § 116.943, subd. 3(a)(1)).

Phase 2: The PFAS Disclosure Reporting Requirement

Phase 2 of Amara's Law activates under Minn. Stat. § 116.943, subd. 2: by September 15, 2026 (extended from January 1, 2026 by MPCA on July 23, 2025), manufacturers of products sold in Minnesota that are not subject to the 2025 bans but contain intentionally added PFAS must submit to the MPCA a detailed disclosure report through the PRISM reporting platform. Required elements include: product description (UPC/SKU); the purpose of each PFAS in the product; the amount of each PFAS by CAS registry number; manufacturer name and contact. A one-time flat fee of $800 per manufacturer covers implementation costs, established by rule finalized December 8, 2025. Annual update reports are due February 1 each year. All information except approved trade secrets becomes publicly accessible after a review period — creating a searchable database that institutional procurement offices will use to impose PFAS-free requirements in advance of the 2032 universal ban.

The Road to 2032: Universal Prohibition

Beginning January 1, 2032, under Minn. Stat. § 116.943, subd. 3(d), no person may sell, offer for sale, or distribute for sale in Minnesota any product containing intentionally added PFAS unless the MPCA commissioner has determined by rule that the use is a "currently unavoidable use" — essential for health, safety, or the functioning of society, with no reasonable alternatives. The MPCA may not grant CUU status to any of the 11 categories already banned in 2025. Between 2025 and 2032, the MPCA commissioner may identify additional product categories for prohibition. The 2025 law was refined by SF 3 (signed June 14, 2025) to expand exemptions for electronic and internal components and to exclude certain children's vehicles from juvenile-products definitions — but these refinements do not affect cleaning products, carpets, or fabric treatments.

Enforcement, Penalties, and MPCA Authority

The MPCA enforces Amara's Law under Minn. Stat. §§ 115.071 and 116.072. Civil penalties may reach $15,000 per day of violation. Broader MPCA environmental enforcement authority authorizes civil penalties up to $30,000 per day and administrative penalties up to $25,000 per violation. Willful violations may result in criminal misdemeanor convictions. The MPCA does not proactively notify individual manufacturers that their products may be prohibited — manufacturers are fully responsible for monitoring applicable regulations. A vendor who has not independently audited their product line cannot rely on an MPCA compliance-assistance visit as a safe harbor. The Minnesota Department of Agriculture (MDA) imposes a parallel checkpoint: the MDA may not register or renew the registration of cleaning products that contain intentionally added PFAS unless the use is determined currently unavoidable (Minn. Stat. § 116.943, subd. 3).

Compliance Actions and Bid-Template Language

Verify 2025 compliance immediately: The January 1, 2025 deadline has passed. Any PFAS-containing cleaning product, floor finish, carpet, or fabric treatment still in your Minnesota inventory or pipeline is in active violation. Conduct a physical audit and remove non-compliant products from service.
Obtain PFAS-free supplier attestations: Request written certification from every floor-care, carpet-care, and fabric-treatment supplier that products sold in Minnesota contain no intentionally added PFAS under Minn. Stat. § 116.943. Retain records for at least 5 years per Minnesota Rule 7026.0080.
Replace PFAS floor finishes: Floor waxes and burnishing finishes are explicitly named as cleaning products under the 2025 prohibition. Non-fluorinated acrylate polymer alternatives are commercially available — pilot-test replacements to validate gloss, durability, and slip resistance.
Prepare for September 2026 PRISM reporting: If your organization manufactures or imports any non-2025-banned product containing intentionally added PFAS for sale in Minnesota, register for the MPCA PRISM platform and prepare for the September 15, 2026 initial reporting deadline. Pay the $800 one-time manufacturer fee at first submission.
Engage MPCA directly: Visit the MPCA PFAS use prohibitions and reporting page for current guidance, PRISM platform updates, and new product-category prohibitions adopted under interim rulemaking authority.
Update all Minnesota bid specifications: Ensure service contracts include PFAS-free language placing compliance burden on product suppliers, creating documentation trails for MDA and MPCA audits.

Bid-template language: "All cleaning products, floor-care products, carpets, fabric treatments, and textile goods supplied or used under this agreement comply with Minnesota's Amara's Law, Minn. Stat. § 116.943, and all MPCA rules promulgated thereunder. Supplier certifies no product supplied contains intentionally added PFAS as defined under Minnesota law, and that all applicable PFAS reporting obligations under Minn. Stat. § 116.943, subd. 2 have been fulfilled. Documentation is retained for a minimum of five (5) years per Minnesota Rule 7026.0080 and will be provided within 30 days of any MPCA or Buyer request."

Primary sources: MPCA prohibitions — pca.state.mn.us PFAS prohibitions; statute — revisor.mn.gov § 116.943; 2025 guidance — pca.state.mn.us 2025 prohibitions; PRISM reporting — pca.state.mn.us PFAS reporting; Minnesota Dept. of Health — health.state.mn.us PFAS products; PFAS Observer — pfas.pillsburylaw.com Minnesota laws.

Primary sources

Related PFAS resources

PFAS state lookup tool — interactive ban calendar across all 50 states.
PFAS in cleaning products: the 2026 state-by-state ban calendar
Green Seal, EcoLogo, Safer Choice & CIMS-GB pathways
Buying smart hub — chemical sourcing and certification guides.

Other states with active PFAS legislation

Each linked state has codified restrictions on intentionally added PFAS in cleaning chemistry. Effective dates, scope, and disclosure rules vary; verify the operative statute for any compliance decision.

Use the PFAS state lookup tool →