EPA Delays PFAS Reporting Under TSCA: New Submission Period Set for 2026

The U.S. Environmental Protection Agency (EPA) has issued an interim final rule delaying the start of the reporting period for the Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) data reporting requirement under TSCA Section 8(a)(7). Originally set to begin in July 2025, the reporting window has been postponed due to technical constraints in the development of the reporting infrastructure.

Updated Submission Period

For Most manufacturers and importers, new reporting window is April 13, 2026 – October 13, 2026.
For Small manufacturers importing PFAS articles only, new reporting window is April 13, 2026 – April 13, 2027

Why the Delay?

EPA needs additional time to complete development and beta testing of its reporting application through the Central Data Exchange (CDX).

Without the delay, submitters might face technical issues, compromising the quality and usability of submitted data.

The extension aligns with Executive Order 14192 (Unleashing Prosperity Through Deregulation) by reducing regulatory burden and ensuring better system readiness.

Legal & Procedural Notes

i. Authority: TSCA Section 8(a)(7), added via the 2020 NDAA.
ii. Rulemaking Type: Interim final rule under APA (Administrative Procedure Act) “good cause” exemption (5 U.S.C. 553(b)(B)), allowing immediate effect without prior public comment.

Public Comments Invitation

EPA is asking for public feedback on this interim final rule.

1. Deadline: Submit comments by June 12, 2025
2. Reference: Use Docket ID: EPA-HQ-OPPT-2020-0549
3. Submit via: Federal eRulemaking Portal

Who’s Affected?

Entities that manufactured (including imported) PFAS between 2011 and 2022, including:

a. Construction (NAICS 23)
b. Manufacturing (NAICS 31–33)
c. Wholesale/Retail trade (NAICS 42, 44–45)
d. Waste management (NAICS 562)

What is NAICS Code?

NAICS stands for North American Industry Classification System. It is a standardized classification system used by the United States, Canada, and Mexico to categorize businesses based on their economic activities.

What are the Reporting Requirements

Under the TSCA Section 8(a)(7) rule, any entity that has manufactured or imported PFAS or PFAS-containing articles since January 1, 2011, is required to report information on:

Chemical identity and structure

i. Categories of use
ii. Production volumes
iii. Byproducts
iv. Disposal methods
v. Exposure information
vi. Health and environmental effects

Resource: 2025-08168.pdf