Question 1

What are the Minnesota PFAS reporting rule requirements?

Accepted Answer

Minnesota’s final PFAS reporting rule requires manufacturers to report all products containing intentionally added PFAS that are sold, offered, or distributed in the state, including online sales. The rule covers a broad product scope, including fluoropolymers such as PTFE. Manufacturers must submit detailed product information, PFAS functions, and concentration ranges through Minnesota’s new PRISM reporting system. A one-time $800 fee per manufacturer applies, and most reported information will be publicly accessible unless trade-secret protection is approved.

Question 2

What is PRISM for PFAS reporting?

Accepted Answer

PRISM (PFAS Reporting and Information System for Manufacturers) is Minnesota’s online platform for submitting PFAS product data. Launched in January 2026, PRISM serves as the centralized system for Minnesota’s PFAS reporting program and is designed to support multi-state adoption in the future. Manufacturers will use PRISM to register, prepare submissions, report PFAS in products, request waivers, and manage trade-secret claims.

Question 3

What is the Minnesota PFAS reporting deadline?

Accepted Answer

The initial Minnesota PFAS reporting deadline is September 15, 2026. In the original rule, the deadline was July 1, 2026, but this was pushed back in an update published on April 15, 2026. This deadline applies to all in-scope products sold or distributed in the state. Beginning February 2027, manufacturers must report all new products containing intentionally added PFAS by February 1 each year. Ongoing re-reporting is not required unless a product changes, making it essential for companies to maintain a scalable, repeatable PFAS tracking process.

Question 4

What is Section 232 and why does it matter for steel, aluminum, and copper imports?

Accepted Answer

Section 232 of the U.S. Trade Expansion Act allows the president to impose tariffs if imports threaten national security. Since 2018, this has led to significant tariffs on steel and aluminum, and in 2025, copper was added. Importers must now provide detailed supply chain data (such as country of smelt, cast, melt, and pour) to avoid duties up to 200%.

Question 5

How can importers stay compliant with Section 232 reporting requirements?

Accepted Answer

Importers should:Collect mill test certificates, certificates of analysis, or supplier attestationsEngage suppliers early to ensure smelt/melt data is availableUse trade compliance software to trace metals back to the smelterWork with compliance experts to interpret CBP updates and avoid costly penalties

Question 6

What are the risks of not complying with Section 232 tariff requirements?

Accepted Answer

If importers cannot prove the country of smelt, cast, melt, or pour, U.S. CBP may assume the material originated from a restricted country (such as Russia). This can trigger a 200% duty, shipment delays, or even having goods stopped at the border. Lack of documentation creates significant financial and operational risks.

Question 7

What are New Mexico PFAS labeling requirements?

Accepted Answer

Under New Mexico PFAS labeling requirements, manufacturers must label products containing intentionally added PFAS starting on January 1, 2027. The label must include a state-approved symbol and be visible prior to purchase. These requirements apply broadly to products containing intentionally added PFAS sold or distributed in the state, subject to specified exemptions.

Question 8

Which products are subject to PFAS labeling requirements in New Mexico?

Accepted Answer

Many products containing intentionally added PFAS are potentially in scope, including complex durable goods, unless specifically exempt.

Question 9

When do PFAS labeling requirements take effect?

Accepted Answer

20.13.2 NMAC is effective on July 1, 2026. The product labeling requirement applies after January 1, 2027, unless an exemption applies or the manufacturer documents compliance with corresponding labeling requirements enacted by another state.

Question 10

How can manufacturers ensure PFAS compliance for labeling?

Accepted Answer

To meet PFAS compliance requirements, manufacturers must identify PFAS in their products, collect supplier declarations, assess risk, and implement labeling processes across physical and digital channels. Many organizations rely on PFAS compliance solutions to centralize data collection, validate supplier inputs, and maintain ongoing regulatory compliance.

Question 11

Why do compliance response times matter for distributors?

Accepted Answer

Distributors compete on trust. OEMs and Tier 1 manufacturers expect fast access to compliance data for RoHS, REACH, PFAS, conflict minerals, and much more. Slow or incomplete responses can lead to escalations, lost deals, or supplier delisting. Fast, accurate responses help protect revenue and customer relationships.

Question 12

How is Assent’s distributor compliance software different from manufacturer compliance tools?

Accepted Answer

Distributors do not create products or manage bills of materials. They manage compliance documents from manufacturers. Assent’s distributor platform is designed for document handling, not material rollups. It centralizes requests, matches them to verified declarations, and automates responses without adding unnecessary complexity.

Question 13

How does Assent help distributors prevent compliance issues before customers ask?

Accepted Answer

Assent shows compliance coverage across the entire SKU catalog. Dashboards highlight missing or expired declarations so teams can fix gaps early. Access to a shared network of supplier-submitted data reduces repeated outreach. This helps distributors stay audit-ready and deliver consistent, reliable compliance data.

Question 14

What are EPR packaging laws, and why do they matter for manufacturers?

Accepted Answer

Extended producer responsibility (EPR) packaging laws make manufacturers financially and operationally responsible for managing their packaging waste at the end of its life. Under these laws, producers must fund recycling, reporting, and waste management programs through Producer Responsibility Organizations (PROs).In the U.S., EPR is state-driven, meaning compliance varies by state. Manufacturers must track packaging data, report to the appropriate PRO, and pay eco-modulated fees based on recyclability and material composition.EPR laws support a circular economy, reduce landfill waste, and help manufacturers meet sustainability goals.

Question 15

How do manufacturers comply with EPR packaging requirements?

Accepted Answer

Compliance typically involves four key steps:Register and join the appropriate Producer Responsibility Organization (PRO).Track and report the types, weights, and recyclability of packaging materials placed on the market.Pay PRO fees, which may vary based on packaging recyclability (eco-modulation).Meet recycling and content targets — for example, post-consumer recycled content in plastics and paper.Manufacturers must also monitor updates to avoid gaps in compliance across states. Using centralized EPR compliance software helps automate reporting and ensures data accuracy across jurisdictions.

Question 16

How can manufacturers prepare for EPR compliance and avoid penalties?

Accepted Answer

The best way to avoid EPR compliance risks is through proactive preparation and consistent data management. Start by identifying where your products are sold, what materials your packaging uses, and whether those materials are in scope for EPR programs. From there, establish internal tracking processes and join a Producer Responsibility Organization (PRO) early.Manufacturers can also reduce costs and risk by designing recyclable or reusable packaging, centralizing reporting data, and automating updates across states as new regulations emerge. Investing in an EPR compliance platform helps ensure you meet reporting deadlines, maintain audit-ready documentation, and stay ahead of rapidly changing state requirements.

Question 17

How does Assent help manufacturers manage EPR packaging compliance?

Accepted Answer

Assent helps manufacturers simplify and scale their EPR compliance across multiple U.S. states. The Assent Sustainability Platform centralizes packaging data, automates reporting to Producer Responsibility Organizations (PROs), and keeps you ahead of evolving requirements.With Assent, you can track material composition, calculate packaging weights, and generate audit-ready reports that align with state-specific EPR laws, from California’s SB 54 to Colorado’s HB 22-1355. The platform also provides real-time regulatory updates, so you’re never caught off guard by new reporting deadlines or scope changes.

Question 18

What is the EU Waste Framework Directive and why does the SCIP database matter for manufacturers?

Accepted Answer

The EU Waste Framework Directive (WFD) is a cornerstone of the European Union’s circular economy strategy, requiring manufacturers to design products for durability, reuse, and waste reduction. A key update in 2018 introduced the SCIP database, the Substances of Concern In articles as such or in complex objects (Products) database,  managed by the European Chemicals Agency (ECHA). Manufacturers, importers, and assemblers must report products containing Substances of Very High Concern (SVHCs) above 0.1% weight-by-weight (w/w) to the SCIP database. This improves supply chain transparency and supports safe recycling and waste handling.

Question 19

Who must submit data to the SCIP database under the Waste Framework Directive?

Accepted Answer

Any company that manufactures, assembles, imports, or distributes products in the EU market containing SVHCs above 0.1% (w/w) must make a SCIP submission.EU-based companies, including first importers have direct legal responsibility.Non-EU suppliers must provide data to their EU partners to maintain market access.The only exception is retailers selling directly and exclusively to end consumers. To determine if you’re in scope, review your supply chain data against the REACH Candidate List, which is updated about every six months.

Question 20

How does SCIP reporting differ from REACH compliance?

Accepted Answer

While both REACH and SCIP address hazardous substances, SCIP goes deeper.REACH focuses on the registration and restriction of chemicals.SCIP requires a granular declaration of SVHCs at the article level, including details like material category, safe use information, and concentration ranges. In short, REACH manages chemicals, while SCIP manages transparency, ensuring every product component containing an SVHC can be identified and safely handled at the end of its life cycle.

Question 21

How can manufacturers efficiently meet SCIP database requirements?

Accepted Answer

Compliance begins with accurate data collection and supplier collaboration. Manufacturers should:Map all products and identify SVHCs.Collect detailed article- and material-level data following ECHA’s IUCLID format.Use a compliance management solution to automate submissions and maintain accuracy.Solutions like Assent’s SCIP compliance software centralize supplier data, track REACH Candidate List updates, and simplify dossier submissions, helping companies shift from reactive compliance to proactive risk management.

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