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EPA Delays TSCA PFAS Reporting Period to 2027

The U.S. EPA has delayed the start of the PFAS Reporting and Recordkeeping Rule data submission period under TSCA section 8(a)(7) to January 31, 2027 or 60 days after a forthcoming final rule, whichever comes first.

The U.S. Environmental Protection Agency (EPA) has issued a final rule, effective April 13, 2026, modifying the start date of the data submission period for the Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Reporting and Recordkeeping Rule under TSCA section 8(a)(7).

The data submission period will now commence on January 31, 2027, or 60 days following the effective date of a forthcoming final rule addressing substantive reporting requirements, whichever occurs earlier.

The submission period for the PFAS Data Reporting Rule will not begin until a successive final action on this rule by the Agency.

Background

The PFAS Reporting Rule, initially finalized in October 2023 pursuant to the FY 2020 National Defense Authorization Act, requires detailed historical reporting of PFAS data. Following previous deadline extensions related to software development delays, the EPA proposed modifications to the rule in November 2025. The current delay provides the Agency with necessary time to review thousands of public comments received on the November proposal, draft a subsequent final rule, update technical guidance, and finalize the Central Data Exchange (CDX) electronic reporting tool.

Who and What to Report

The rule applies to any entity that has manufactured or imported PFAS, or PFAS-containing articles, for a commercial purpose at any time since January 1, 2011. The following information is required to be submitted to EPA:

  • Chemical identity

  • PFAS uses

  • Production volume

  • Disposal methods

  • Exposure pathways

  • Hazards

When to Report

All information reported to EPA in response to the abovementioned requirements must be submitted during the applicable submission period. Below is a summary of the compliance timelines:

Reporting Category

Start of Submission Period

Duration of Submission Period

Standard Manufacturers and Importers

January 31, 2027 (or 60 days post-effective date of forthcoming final rule, whichever is earlier)

6 months

Small Manufacturers, pursuant to 40 CFR 704.3 (reporting exclusively from article imports)

January 31, 2027 (or 60 days post-effective date of forthcoming final rule, whichever is earlier)

12 months

The Final Rule can be accessed here

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