Perfluoroalkyl and polyfluoroalkyl substances (PFAS) are widely used, long-lasting chemicals that break down very slowly over time and are often referred to as “forever chemicals.” There are thousands of PFAS compounds, and they are found in a broad range of consumer, commercial, and industrial products. Scientific studies have shown that exposure to certain PFAS in the environment may be associated with adverse health effects in humans and animals, including impacts on the immune and reproductive systems and an increased risk of certain cancers.
EPA Regulatory Initiatives
Because of these concerns, the U.S. Environmental Protection Agency (EPA) has undertaken numerous actions to reduce PFAS releases to the environment and has issued various rulemakings to collect information on PFAS manufacture, use, and disposal.
In this blog we discuss EPA’s October 2023 final rule that established a one-time PFAS reporting and recordkeeping requirement under the Toxic Substances Control Act (TSCA) Section 8(a)(7). This rule requires any entity that manufactured or imported PFAS, including in mixtures or articles, for commercial purposes in any year since 2011 to report specific PFAS-related information to the EPA.
The agency has subsequently proposed revisions to the regulation that would create several reporting exemptions, including an exemption for PFAS use in research and development (R&D) activities, as discussed below.
Data Submission Requirements
For non-exempt entities, the following information must be reported to the EPA for each PFAS substance or mixture:
- Common or trade name, chemical identity, and molecular structure
- Categories, or proposed categories, of use
- Total amount manufactured, imported, or processed for each use category
- Description of byproducts resulting from manufacture, processing, use, or disposal
- Existing information concerning environmental and health effects
- Number of individuals exposed in the workplace, including reasonable estimates of future exposures, and the duration of exposure
- Methods used for PFAS disposal
Reporting Deadlines
The PFAS reporting period was originally scheduled to begin on November 12, 2024. However, an interim final rule subsequently extended the reporting deadline to October 13, 2026, for most manufacturers and importers. Small businesses reporting exclusively on imported articles containing PFAS were granted an additional six months, until April 13, 2027, to submit their reports.
More recently, an April 2026 rule further extended the reporting period by establishing a new reporting submission start date of January 31, 2027, or 60 days after the effective date of a final rule based on the November 2025 proposed rule, whichever is earlier. The final rule will establish the revised reporting deadlines and provide additional implementation details.
Proposed Exemptions
The proposed rule significantly modifies the scope of the EPA’s PFAS reporting requirements. According to the agency, the proposed changes are intended to preserve reporting for activities where manufacturers and importers are reasonably expected to possess relevant information, while exempting activities for which such information is less likely to be known or unable to be determined.
The proposed exemptions are included below:
- Chemicals used for research and development (R&D)
- PFAS manufactured or imported in mixtures or products at concentrations of 0.1% or less
- Imported articles containing PFAS
- Certain byproducts
- Impurities
- Non-isolated intermediates
The EPA is also proposing technical corrections to clarify reporting requirements for certain data fields and to adjust the reporting period.
According to the EPA’s Agency Rule List issued on July 3, 2026 [RIN: 2070-AL29], the agency is expected to issue a final rule addressing these exemptions by the end of July 2026. As of the date of this blog post, it has not yet been issued. Organizations should continue to monitor the status of the rule to determine if the changes affect their reporting obligation.
Contact us today to learn more about PFAS reporting requirements and how the expected regulatory changes may affect your operations.
This blog was written by Beth Graham, Director of Quality, Research, and Training at Safety Partners.
