On March 30, 2026, the U.S. Environmental Protection Agency (EPA) proposed extending the reporting deadline for the Health and Safety Data Reporting Rule under the Toxic Substance Control Act (TSCA) by one year to May 21, 2027. 91 Fed. Reg. 15582. According to EPA, it intends the proposed extension to delay compliance with the one-time reporting rule during EPA’s ongoing reconsideration of the rule. EPA notes that it is proposing to extend the deadline because it determined additional time is necessary to alleviate the compliance burdens associated with the one-time reporting rule while EPA considers potential modifications to the regulations, including aligning the rule with Executive Order 14219 “Ensuring Lawful Governance and Implementing the President’s ‘Department of Government Efficiency’ Deregulatory Initiative” (90 Fed. Reg. 10583 (Feb. 19, 2025)) and EPA’s Powering the Great American Comeback Initiative Pillar I: Clean Air, Land, and Water for Every American. EPA states that it is not reopening or reconsidering provisions of the underlying regulations other than the submission deadline. The December 13, 2024, final reporting rule requires manufacturers (including importers) of the following 16 chemical substances to submit copies and lists of certain unpublished health and safety studies to EPA:
- 4,4-Methylene bis(2-chloraniline);
- 4-tert-octylphenol(4-(1,1,3,3-Tetramethylbutyl)-phenol);
- Acetaldehyde;
- Acrylonitrile;
- Benzenamine;
- Benzene;
- Bisphenol A (BPA);
- Ethylbenzene;
- Naphthalene;
- Vinyl chloride;
- Styrene;
- Tribromomethane (bromoform);
- Triglycidyl isocyanurate;
- Hydrogen fluoride;
- N-(1,3-Dimethylbutyl)-N′-phenyl-p-phenylenediamine (6PPD); and
- 2-anilino-5-[(4-methylpentan-2-yl) amino]cyclohexa-2,5-diene-1,4-dione (6PPD-quinone).
Comments on the proposed extension are due April 29, 2026. More information on the final reporting rule is available in our December 23, 2024, memorandum.
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