EPA Delays TSCA Section 8(a)(7) PFAS Reporting Period

Affected manufacturers or importers of PFAS or PFAS-containing articles will have an extra eight months, until July 11, 2025, to prepare

On Sept. 5, the U.S. Environmental Protection Agency delayed the data submission period for new reporting requirements for per- and polyfluoroalkyl substances (PFAS) under the Toxic Substances and Control Act (TSCA). The final rule requires any person who manufactures or imports or has manufactured or imported PFAS or PFAS-containing articles any time since Jan. 1, 2011, to electronically report on specific PFAS uses, production volumes, disposal, exposures, and hazards.

This data submission period was scheduled to begin Nov. 12, but due to budgetary issues and resource limitations, EPA delayed the beginning of the reporting period until July 11, 2025.

What does this mean for manufacturers and importers?

According to EPA, this robust data collection is necessary to better research, regulate, and monitor PFAS to protect human health and the environment.

Because of the final rule's extensive requirements for data gathering and reporting, it has the potential to capture one of the largest datasets of PFAS manufactured and used in the U.S. However, the level of current and historical data required by the final rule creates a significant burden for affected companies, especially given that the final rule does not have a de minimis exemption that would allow companies to exclude reporting PFAS used in minimal concentrations.

Companies that manufacture or use PFAS, or that import articles, materials, or products that may contain PFAS, can use the delayed reporting period to their advantage by conducting their due diligence with suppliers. While most businesses will be required to complete all reporting by Jan. 11, 2026, small businesses reporting data only on importing PFAS contained in articles will have until July 11, 2026, to submit reports, according to EPA.