Minnesota's PFAS Reporting Deadline Hits July 1: What HVACR Manufacturers and Contractors Need to Know About the Expanding State Patchwork

Two regulatory threads that HVACR manufacturers and contractors have been tracking separately for years are increasingly converging into a single, more complex compliance landscape: the growing state-by-state patchwork of PFAS chemical regulations, and the continued evolution of building codes tied to A2L refrigerant adoption. Regulatory experts from AHRI laid out exactly where both of these issues currently stand, and the picture that emerges is one of accelerating complexity that contractors and manufacturers need to actively monitor rather than assume is settled.

Understanding Why PFAS Has Become an HVAC Industry Issue

PFAS, short for per- and polyfluoroalkyl substances, refers to a large class of chemicals long valued across many industries for their water-, heat-, and grease-resistant properties — exactly the properties that have made them useful in numerous manufactured items, including, as it turns out, various HVAC components and certain refrigerants. The challenge is that these same chemical properties that make PFAS useful also make them persistent in the environment and capable of accumulating in the human body, raising the health concerns that are now driving an expanding wave of state-level regulation.

Nicole Colantonio, senior director of regulatory affairs at AHRI, has been explicit that PFAS regulation is becoming a major regulatory focus, particularly concentrated at the state level rather than emerging as a single coordinated federal standard. This state-by-state pattern is precisely what creates the compliance complexity manufacturers and contractors now need to navigate, since requirements, deadlines, and exemptions vary meaningfully from state to state with no unified national framework to simplify compliance.

The State-Specific Deadlines That Matter Right Now

Maine has already established one of the more concrete regulatory timelines in this space: effective January 1, 2040, it will no longer be legal to sell or distribute HVACR equipment containing intentionally added PFAS, including refrigerants, within the state. While 2040 may sound distant, Maine has provided exemptions for used HVACR equipment, parts for HVACR equipment, and refrigerants subject to the EPA's SNAP program, meaning manufacturers and distributors operating in Maine need to understand precisely which products fall under the exemption framework versus which face the eventual prohibition.

Minnesota's timeline is considerably more immediate and demands attention right now rather than years from now. Manufacturers of products containing intentionally added PFAS are required to submit an initial compliance report by July 1, 2026 — a deadline that is now imminent — with annual reporting beginning February 1, 2027 thereafter. Minnesota has built a dedicated reporting infrastructure for this requirement, the PRISM system, short for PFAS Reporting Information System for Manufacturers, which is now available and operational for manufacturers who need to begin the reporting process.

New Mexico presents a different and, according to Colantonio, more immediately burdensome challenge centered specifically on product labeling requirements rather than reporting obligations. She has described New Mexico's labeling requirements as very extensive, generating substantial and burdensome processing labor for manufacturers navigating compliance right now. Industry stakeholders are actively pushing for relief on this front, specifically advocating for a labeling exemption for complex durable goods — a category that would presumably include much HVACR equipment, given its technical complexity relative to simpler consumer products that PFAS labeling rules were arguably designed around in the first place.

The Parallel A2L Building Code Story

Running alongside the PFAS regulatory patchwork is the continued evolution of building codes tied to A2L refrigerant adoption, a process that remains far from fully settled even though A2L equipment has already become the OEM standard for new residential and light commercial systems. AHRI maintains a live A2L Refrigerant Building Code Map tracking exactly where state and local jurisdictions have updated their building codes or passed legislation to allow equipment using A2L refrigerants — a resource contractors should be checking regularly rather than assuming their local code already reflects full A2L authorization.

A separate, less publicly discussed regulatory thread that AHRI's regulatory team considers potentially even more significant than the A2L code questions involves a proposed change to the ASME Boiler and Pressure Vessel Code, Section VIII. According to AHRI's regulatory affairs team, the proposed change would eliminate three long-standing exemptions currently applying to many HVACR components — exemptions that have been in place for decades, in some cases as long as forty years, without any documented safety incident motivating their removal. AHRI and twenty-nine other organizations filed a formal appeal after more than 250 negative public comments were submitted during review and, notably, every single one was rejected without explanation. The framing from AHRI's side is that this isn't a safety-driven change at all, but rather what they characterize as regulatory scope creep with no underlying safety justification.