Effective May 13, 2025, the United States Environmental Protection Agency (EPA) issued an interim rule extending the data submission period for the Toxic Substances Control Act (TSCA) section 8(a)(7) perfluoroalkyl and polyfluoroalkyl substances (PFAS) reporting requirement (PFAS Reporting Rule).
PFAS, also known as "forever chemicals" due to their persistence in the environment, have been linked to health and safety issues. The PFAS Reporting Rule requires manufacturers (including importers) of PFAS and PFAS containing articles in any year since January 1, 2011, to electronically report information regarding PFAS uses, production volumes, disposal, exposures, and hazards to enable EPA to identify the amount of PFAS present in the United States. The reporting period was set to begin on July 11, 2025, and end on January 11, 2026, for most businesses, while small businesses were given until July 11, 2026. Citing delays in the completion of EPA's reporting application to collect this data, EPA's action extends the data submission period to begin on April 13, 2026, and end on October 13, 2026, with an alternate end date for small businesses of April 13, 2027.
This reprieve will come as good news for businesses having to comply with the PFAS Reporting Rule. EPA is also considering reopening certain aspects of the rule to public comment. Therefore, it is possible that there will be future substantive changes to the PFAS Reporting Rule that will impact the information businesses must provide. We are closely following this issue.
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