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PFAS Reporting Requirements

For pesticide products, the registrant of any products sold, offered for sale, or distributed for sale in the state of Minnesota that contain intentionally added PFAS is required to report.

For fertilizers, specialty fertilizers, soil and plant amendments, and agricultural liming products, the manufacturer of any products sold, offered for sale, or distributed for sale in the state of Minnesota that contain intentionally added PFAS is required to report. “Manufacturer” is defined in MINN. STAT. §18C.005 Subd. 19(a). If more than one entity meets the definition of manufacturer, the MDA will consider the party who controls the formulation of the product to be the manufacturer.

Who is responsible for reporting intentionally added PFAS in a product to the MDA?

For pesticide products, the registrant of any products sold, offered for sale, or distributed for sale in the state of Minnesota that contain intentionally added PFAS is required to report.

For fertilizers, specialty fertilizers, soil and plant amendments, and agricultural liming products, the manufacturer of any products sold, offered for sale, or distributed for sale in the state of Minnesota that contain intentionally added PFAS is required to report. “Manufacturer” is defined in MINN. STAT. §18C.005 Subd. 19(a). If more than one entity meets the definition of manufacturer, the MDA will consider the party who controls the formulation of the product to be the manufacturer.

No

Any product sold, offered for sale, or distributed for sale in Minnesota that is currently regulated or registered by the MDA and contains intentionally added PFAS must be reported to the MDA. This includes pesticides, fertilizers, specialty fertilizers, soil amendments, plant amendments, and agricultural liming products. If packaging for these products contains intentionally added PFAS, it must be reported to the Minnesota Pollution Control Agency (MPCA). All other PFAS-containing products are regulated by the MPCA.

Which PFAS-containing products do I need to report to the MDA versus the Minnesota Pollution Control Agency?

Any product sold, offered for sale, or distributed for sale in Minnesota that is currently regulated or registered by the MDA and contains intentionally added PFAS must be reported to the MDA. This includes pesticides, fertilizers, specialty fertilizers, soil amendments, plant amendments, and agricultural liming products. If packaging for these products contains intentionally added PFAS, it must be reported to the Minnesota Pollution Control Agency (MPCA). All other PFAS-containing products are regulated by the MPCA.

No

No, all product registrants, manufacturers, and guarantors are responsible for determining whether their products (pesticide, fertilizer, specialty fertilizer, soil and plant amendments, agricultural liming products, etc.) contain intentionally added PFAS and reporting to the MDA. Registrants will be asked to indicate whether their products contain intentionally added PFAS on their product renewal forms starting in 2024and on new product registration applications.

The MDA has a preliminary list of pesticide active and inert ingredients that have been identified as PFAS by the Minnesota definition which can be used for general guidance; however, these lists are not comprehensive and may be subject to change.

Will the MDA notify me if my product contains PFAS?

No, all product registrants, manufacturers, and guarantors are responsible for determining whether their products (pesticide, fertilizer, specialty fertilizer, soil and plant amendments, agricultural liming products, etc.) contain intentionally added PFAS and reporting to the MDA. Registrants will be asked to indicate whether their products contain intentionally added PFAS on their product renewal forms starting in 2024and on new product registration applications.

The MDA has a preliminary list of pesticide active and inert ingredients that have been identified as PFAS by the Minnesota definition which can be used for general guidance; however, these lists are not comprehensive and may be subject to change.

No

Beginning January 1, 2026, and annually thereafter.

When do I have to report intentionally added PFAS ingredients to the MDA?

Beginning January 1, 2026, and annually thereafter.

No

For pesticide products, the registrant of any products sold, offered for sale, or distributed for sale in the state of Minnesota that contain intentionally added PFAS is required to report.

For fertilizers, specialty fertilizers, soil and plant amendments, and agricultural liming products, the manufacturer of any products sold, offered for sale, or distributed for sale in the state of Minnesota that contain intentionally added PFAS is required to report. “Manufacturer” is defined in MINN. STAT. §18C.005 Subd. 19(a). If more than one entity meets the definition of manufacturer, the MDA will consider the party who controls the formulation of the product to be the manufacturer.

Any product sold, offered for sale, or distributed for sale in Minnesota that is currently regulated or registered by the MDA and contains intentionally added PFAS must be reported to the MDA. This includes pesticides, fertilizers, specialty fertilizers, soil amendments, plant amendments, and agricultural liming products. If packaging for these products contains intentionally added PFAS, it must be reported to the Minnesota Pollution Control Agency (MPCA). All other PFAS-containing products are regulated by the MPCA.

No, all product registrants, manufacturers, and guarantors are responsible for determining whether their products (pesticide, fertilizer, specialty fertilizer, soil and plant amendments, agricultural liming products, etc.) contain intentionally added PFAS and reporting to the MDA. Registrants will be asked to indicate whether their products contain intentionally added PFAS on their product renewal forms starting in 2024and on new product registration applications.

The MDA has a preliminary list of pesticide active and inert ingredients that have been identified as PFAS by the Minnesota definition which can be used for general guidance; however, these lists are not comprehensive and may be subject to change.

Registrants will be able to submit information on whether their product contains intentionally added PFAS as part of their renewal forms or registration applications (yes or no question).

The MDA has developed a form through which registrants can submit the additional required information about their products with intentionally added PFAS (e.g., PFAS chemical name, weight percent, purpose). Registrants will be notified when the form is available.  

According to Minnesota law, beginning January 1, 2026, pesticide registrants and manufacturers of fertilizers, specialty fertilizers, plant and soil amendments, and agricultural liming products must annually provide a statement that a product contains no intentionally added PFAS or, for products that contain intentionally added PFAS, the following information must be submitted:

  • the name and purpose for which PFAS are used in the pesticide, including in any product components;
  • the amount of each PFAS in the product, identified by its name, chemical structure, chemical abstracts service registry number, or other unique method approved by the commissioner; and
  • any additional information required by the commissioner.

Beginning January 1, 2026, and annually thereafter.

The law only requires information on product ingredients that meet the Minnesota definition of PFAS be submitted. CSFs will not be required for PFAS reporting.

Containers are not considered part of a pesticide product and thus pesticide containers will not be regulated by the MDA. Containers, including those that are fluorinated, are regulated by the Minnesota Pollution Control Agency. Questions about regulation of fluorinated containers can be directed to: pfasinfo.pca@state.mn.us.

No.

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