- within Environment topic(s)
- in United States
- with readers working within the Environment & Waste Management industries
- within Environment, Government, Public Sector, Food, Drugs, Healthcare and Life Sciences topic(s)
On November 10, 2025, the U.S. Environmental Protection Agency (EPA) announced proposed changes to its reporting requirements for per- and polyfluoroalkyl substances (PFAS) under the Toxic Substances Control Act (TSCA). These changes aim to make compliance more practical for businesses while ensuring that regulators receive data necessary to regulate these compounds under the TSCA.
In 2023, EPA finalized a one-time PFAS reporting rule under TSCA Section 8(a)(7), requiring manufacturers and importers to report data on PFAS produced or imported between 2011 and 2022. While intended to improve transparency, the rule imposed significant compliance costs—estimated at nearly $1 billion—without clear implementation standards. The new proposal seeks to reduce unnecessary burdens while maintaining robust data collection by implementing the following changes:
- Exemptions for Low-Risk Activities: Reporting would no longer be required for PFAS present in mixtures or products at concentrations of 0.1% or lower, imported articles, certain byproducts, impurities, research and development chemicals, and non-isolated intermediates. With respect to imports, the exemption applies specifically to PFAS imported as part of an "article"—which TSCA defines as a manufactured item with a specific shape or design whose function depends on that shape/design and which does not change chemical composition during use (e.g., finished goods like electronics, textiles, or machinery parts).
- Technical Clarifications: EPA plans to refine data fields and correct ambiguities to make reporting clearer and more efficient.
- Adjusted Submission Period: The current rule requires one-time reporting by manufacturers and importers over a six-month period between April 13, 2026, and October 13, 2026. The proposed change would result in the submission period beginning 60 days after the effective date of the final rule and lasting for an additional three months.
These changes reflect EPA Administrator Lee Zeldin's commitment to "commonsense regulation" that balances environmental protection with economic practicality. According to Zeldin, the revisions will allow EPA to collect the most relevant PFAS data without imposing "ridiculous requirements on manufacturers, especially small businesses."
The next step in the rulemaking process is publication of the proposal in the Federal Register, after which EPA will open a 45-day public comment period under docket #EPA-HQ-OPPT-2020-0549. Stakeholders—including manufacturers, importers, and environmental advocacy groups—are encouraged to provide input on the proposed revisions.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
