ARTICLE
4 September 2025

EPA Submits Proposed Rule Revising TSCA Section 8(a)(7) PFAS Rule To OMB For Review

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Bergeson & Campbell

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Bergeson & Campbell, P.C. is a Washington D.C. law firm focusing on chemical product approval and regulation, product defense, and associated business issues. The Acta Group, B&C's scientific and regulatory consulting affiliate provides strategic, comprehensive support for global chemical registration, regulation, and sustained compliance. Together, we help companies that make and use chemicals commercialize their products, maintain compliance, and gain competitive advantage as they market their products globally.
According to the Office of Management and Budget (OMB) website, on August 29, 2025, the U.S. Environmental Protection Agency (EPA) submitted a proposed rule entitled "Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping under the Toxic Substances Control Act (TSCA); Revision to Regulation" to OMB for review.
United States Environment

According to the Office of Management and Budget (OMB) website, on August 29, 2025, the U.S. Environmental Protection Agency (EPA) submitted a proposed rule entitled "Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping under the Toxic Substances Control Act (TSCA); Revision to Regulation" to OMB for review. Because the proposed rule has not been published in a Unified Agenda, no summary is available. When EPA postponed the reporting period from July 11, 2025, to April 13, 2026, EPA indicated that it was separately considering reopening certain aspects of the October 2023 rule to public comment. As reported in our May 4, 2025, blog item, on May 2, 2025, a coalition of chemical companies submitted a TSCA Section 21 petition seeking "'the typical TSCA 8(a) reporting exemptions (e.g., by-products, impurities, articles, [research and development (R&D)] materials, and a production volume threshold)' that apply in other TSCA Section 8(a) reporting rules." According to a May 22, 2025, letter from EPA, on May 16, 2025, the coalition withdrew its petition via e-mail to EPA Administrator Lee Zeldin and "EPA now considers this petition closed." The proposed rule submitted to OMB is not publicly available.

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