U.S. EPA Proposes Amendments to PFAS Reporting Rule under TSCA

Targeted audience	U.S. domestic manufacturers, U.S. importers and upstream suppliers
Products concerned	Consumer products
Key industries concerned with this insight	Consumer products
Application date	2 months after the effective date of the final rule
Main content or requirements	On November 13, 2025, the U.S. Environmental Protection Agency (EPA) proposed exemptions to PFAS reporting requirements under the Toxic Substances Control Act (TSCA) and adjusted the data submission period.
Reference	Click here

On November 13, 2025, the U.S. Environmental Protection Agency (EPA) released a proposal to improve the scope of its perfluoroalkyl and polyfluoroalkyl substances (PFAS) reporting regulations under the Toxic Substances Control Act (TSCA) to make them more practical and implementable and reduce unnecessary, or potentially duplicative, reporting requirements for businesses while maintaining the ability to obtain important use and safety information on PFAS. 

The EPA published a final rule 40 CFR 705 for reporting and recordkeeping requirements for per- and polyfluoroalkyl substances (PFAS) under the Toxic Substances Control Act (TSCA) Section 8(a)(7) in October 2023 and subsequently published direct final rules in September 2024 and again in May 2025 to delay the reporting period for the PFAS reporting rule. The PFAS reporting rule requires manufacturers and importers (including those dealing with articles) to report detailed information about PFAS substances used between 2011 and 2022. 

The proposed exemptions to the reporting requirements are for: 

• PFAS manufactured (including imported) in mixtures or products at concentrations 0.1% or lower; 
• Imported articles; 
• Certain byproducts; 
• Impurities; 
• Research and development chemicals; and 
• Non-isolated intermediates.  

The EPA also proposed the submission period, from April 13, 2026 - October 13, 2026(to April 13, 2027 for small article importers), to begin 2 months after the effective date of the final rule and last for three months. 

Public comments must be received on or before December 29, 2025.

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