| 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 | April 13, 2026 |
| Main content or requirements | U.S. EPA Further Delays PFAS Reporting Deadline Under TSCA |
| Reference | Click here |
On May 13, 2025, the U.S. Environmental Protection Agency (EPA) published an interim final rule in the Federal Register, officially postponing the start of the PFAS reporting period under the Toxic Substances Control Act (TSCA). This marks the second delay in the implementation of this reporting requirement, originally finalized in October 2023.
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) on October 11, 2023 and subsequently published a direct final rule on September 5, 2024 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 rule is designed to improve the EPA’s understanding of the scope and use of PFAS across industries, informing future risk assessments and regulatory actions.
The EPA cited the ongoing development and testing of its electronic reporting system as the reason for the extension. Additionally, the Agency has signaled that it may reopen portions of the rule for further public comment, suggesting that further revisions to reporting requirements may be on the horizon.
Under the interim final rule, the data submission period will begin on April 13, 2026, and last for six months: April 13, 2026, through October 13, 2026. And for small article importers, the submission period will begin on April 13, 2026, and last for 12 months: April 13, 2026, through April 13, 2027.
This interim final rule is effective on May 13, 2025. The EPA is currently accepting public comments on the interim final rule and the comments must be received on or before June 12, 2025.
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