Table of Contents
Minnesota has enacted one of the most far-reaching PFAS product laws in the United States — second only to Maine in scope.
Under Minnesota House File 1000 (HF 1000), the state established a phased prohibition on intentionally added PFAS in consumer products, beginning with specific product categories and culminating in a near-total PFAS phase-out by 2032.
This is not a disclosure-only law. It is a product access law.
What Is Minnesota HF 1000?
HF 1000, enacted in 2023 and codified primarily in Minn. Stat. §116.943, regulates consumer products containing intentionally added PFAS.
The law:
- bans PFAS in defined product categories starting in 2025,
- requires product-specific disclosures to the Minnesota Pollution Control Agency (MPCA),
- allows limited exemptions for currently unavoidable uses (CUU),
- and establishes a statewide PFAS prohibition by 2032.
HF 1000 does not regulate PFAS manufacturing broadly, and it does not impose a chemical-inventory reporting regime.
How Minnesota Defines PFAS and “Intentionally Added”
HF 1000 uses a class-based definition of PFAS, covering fluorinated organic chemicals containing at least one fully fluorinated carbon atom.
PFAS are considered “intentionally added” when they are deliberately introduced during manufacturing to provide a specific function, characteristic, or performance benefit.
This distinction is critical: the law targets functional PFAS use, not trace contamination.
Product Categories Restricted Starting January 1, 2025
Beginning January 1, 2025, Minnesota prohibits the sale, offer for sale, or distribution of specified product categories that contain intentionally added PFAS.
Covered product categories include:
- carpets and rugs
- cleaning products
- cookware
- cosmetic products
- dental floss
- fabric treatments
- juvenile products
- menstruation products
- textile furnishings
- ski wax
- upholstered furniture
This is not a blanket PFAS ban. Only products explicitly listed in statute are restricted at this stage.
Full PFAS Phase-Out by January 1, 2032
Minnesota HF 1000 goes further than most state laws.
Starting January 1, 2032:
No product containing intentionally added PFAS may be sold in Minnesota, unless the use is deemed currently unavoidable for health, safety, or critical societal functioning.
This provision establishes one of the strongest PFAS end-state prohibitions in the U.S.
Information Disclosure Requirements (Product-Specific)
HF 1000 requires manufacturers of covered products containing intentionally added PFAS to submit information to the Minnesota Pollution Control Agency (MPCA).
Current deadline
- July 1, 2026 (extended from the original January 1, 2026 date)
Required information includes:
- a brief product description and identifier (e.g., SKU or UPC),
- the purpose for which PFAS is used,
- the amount of PFAS in the product,
- manufacturer contact information,
- and any additional information requested by MPCA.
This is product-level disclosure, not annual chemical reporting.
What HF 1000 Does Not Require
To avoid common misinterpretations, HF 1000 does not:
- require annual PFAS reporting by all manufacturers or importers,
- create a PFAS spill or release reporting program,
- regulate PFAS as chemicals in isolation,
- impose wastewater or environmental discharge limits.
Those obligations fall under other state or federal programs, not HF 1000.
Waivers, Extensions, and “Currently Unavoidable Use”
The MPCA may grant:
- deadline extensions,
- reporting waivers,
- or CUU determinations,
where:
- equivalent information is already available,
- additional time is needed to comply,
- or PFAS use is essential for health, safety, or critical societal function.
CUU determinations are limited, reviewable, and not automatic.
Enforcement and Oversight
HF 1000 authorizes MPCA to:
- request certificates of compliance,
- require testing or supporting documentation,
- notify sellers of prohibited products,
- and recover administrative costs.
Penalties are handled under Minnesota’s existing enforcement authorities rather than through a new penalty schedule in HF 1000.
What This Means for Manufacturers
Minnesota HF 1000 forces a shift from declarations to material-level accountability.
Manufacturers must:
- know where PFAS are intentionally used,
- understand which product categories trigger bans,
- plan reformulation ahead of 2032,
- and maintain defensible supplier data.
Companies waiting until 2030 to act will already be behind.
How Minnesota Fits into the U.S. PFAS Landscape
Minnesota now sits alongside:
- Maine (LD 1503 — phased bans + CUU),
- Connecticut (product-category bans),
- Illinois (foam + consumer products),
as a top-tier PFAS restriction state.
HF 1000 is a signal: PFAS-free product design is becoming the default, not the exception.
Final Takeaway
Minnesota HF 1000 is one of the most consequential PFAS product laws in the U.S.
- 2025: product-category bans begin
- 2026: product-specific disclosures due
- 2032: near-total PFAS phase-out
Manufacturers that treat HF 1000 as a future problem will face rushed reformulation and lost market access. Manufacturers that act now will scale across every PFAS-regulated state.