The RV Industry Association (RVIA) called for revisions to Minnesota’s proposed PFAS reporting rule during a public hearing held by the Minnesota Pollution Control Agency on Thursday, May 22.
Bill Erny, the association’s senior manager of regulatory affairs, testified on behalf of the industry, citing feasibility concerns related to the rule’s implementation timeline and reporting requirements.
According to a News and Insights report of RVIA, the proposed rule would require manufacturers to report products containing intentionally added per- and polyfluoroalkyl substances (PFAS) that are sold, offered for sale, or distributed in Minnesota.
A reporting deadline of January 1, 2026, and associated fees are included in the plan, which is currently open to public comment for 30 days.
Erny told regulators the RV industry faces significant challenges in meeting the proposed requirements due to the “complexity of RVs and the rule’s short timeline.”
He urged the agency to collaborate with the RV sector to ensure environmental goals are met without disrupting business operations in the state.
During his testimony, Erny requested that the agency delay the reporting deadline by at least 12 months.
He said the extension would allow time to finalize guidance, test reporting tools, and give manufacturers sufficient lead time to gather necessary information from their suppliers.
He also recommended that the agency allow aggregate reporting at the vehicle level, arguing that requiring data on each individual component would impose a disproportionate burden on manufacturers.
Erny further requested the exclusion of internal vehicle components from the reporting mandate.
He explained that parts such as internal wiring, electronics, and sealed gaskets are integrated into vehicle systems and not accessed during typical use or handling by consumers.
In addition, RVIA asked the agency to adopt a due diligence standard consistent with the U.S. Environmental Protection Agency’s definition of “known or reasonably ascertainable.” Erny said such a standard would align with federal guidance and provide realistic expectations for industry compliance.
The RV Industry Association also submitted formal written comments reflecting the views of its PFAS Working Group and member companies.