Minnesota’s Pollution Control Agency (MPCA) held a public hearing on May 22, 2025 concerning its proposed rules that would implement PFAS-in-products reporting requirements and associated fees on entities covered by Amara’s Law (which we have previously discussed here and here).  The Minnesota Office of Administrative Hearings, which presided over the May hearing, has announced that it will be accepting post-hearing comments on the proposed rules through June 23, 2025, and that rebuttal comments will be accepted from June 24, 2025, through June 30, 2025.  Post-hearing comments may include any new comments on the proposed rules; rebuttal comments must only respond to public comments received through the June 23 deadline and cannot raise new issues. 

Comments submitted to MPCA to date have focused chiefly on the feasibility of meeting the proposed rule’s January 1, 2026, initial reporting deadline, and on the proposed due diligence standard to be applied to regulated entities under the rule, which would require entities covered under the statute to request detailed disclosure of information from their supply chain “until all required information is known.”  Materials from the hearing can be found here.  If your company is covered under MPCA’s proposed PFAS-in-products reporting rules, it may be worth considering the submittal of comments before the June 23 commenting deadline, as well as monitoring the comments that are received by June 23 to evaluate whether rebuttal comments would be advisable. Comments may be submitted electronically (after signing up for the state’s electronic commenting system here).