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On November 10, 2025, the U.S. Environmental Protection Agency (EPA) released a proposed rule to amend the Toxic Substances Control Act (TSCA) regulation for reporting and recordkeeping requirements for perfluoroalkyl and polyfluoroalkyl substances (PFAS). Comments must be received on or before December 29, 2025.
The amendment is considered necessary by the EPA to avoid duplicative data collection, reduce burdens on small manufacturers, and ensure reporting applies only to entities likely to possess relevant information.
The proposed rule incorporates certain exemptions and other modifications to the reporting regulation under 40 CFR 705. The proposed exemptions include:
PFAS manufactured (including imported) in mixtures or products at concentrations of 0.1% or lower;
Imported articles;
Certain byproducts;
Impurities;
Research and development chemicals; and
Non-isolated intermediates.
The PFAS data reporting period is also amended as follows: the submission period will begin 60 days after the effective date of the final rule and will last for three months.
EPA also proposes to clarify that OECD-harmonized templates (OHTs) are required for unpublished health and environmental effects studies on reportable PFAS—but not for exposure data already submitted via structured fields. Additionally, the agency plans to update and refine consumer and commercial product category names and descriptions (e.g., CC303, CC217–CC221, CC305).
The proposed rule can be accessed here.
Background
On June 28, 2021, EPA proposed the PFAS reporting rule under TSCA section 8(a)(7). This rule require a PFAS manufacturer (including importer) to report data between 2011-2022 to EPA. However, no reporting exemption or thresholds are proposed as other TSCA reporting rule does. The reporting deadline was also moved twice due to the development of IT infrastructure and the need for industry beta testing. The latest amended reporting priod begins on April 13, 2026 and ends on October 13, 2026. (See more)
