- with Senior Company Executives and HR
On April 9, 2026, the Environmental Protection Agency (EPA) announced a long-anticipated delay in the reporting window for the per- and polyfluoroalkyl substances (PFAS) reporting rule under the Toxic Substances Control Act (TSCA). In October 2023, EPA imposed a one-time requirement under TSCA on entities that manufactured (including imported) PFAS or PFAS containing products between 2011 and 2022 to submit to EPA information regarding PFAS exposure and environmental and health effects. After two extensions due to delays in developing the web-based reporting portal, the reporting window under the rule was set to open on April 13, 2026, and close on October 13, 2026. As the opening date approached, EPA proposed a partial rollback of the rule that would both exempt certain categories of PFAS from the reporting requirements and change the reporting period (a prior PFAS Press blog post discusses the proposed rollback) but until today it had not formally cancelled the original start date. With the announcement, EPA resolved the uncertainty, confirming that reporting will not commence on April 13 and instead will begin only 60 days after the revised rule becomes effective (although questions still remain as to whether EPA will shorten the reporting window from the original six months to the proposed three months). EPA plans to issue a final rule on reporting later this year, with updated guidance and reporting tools accompanying the revised requirements.
Akin will continue to monitor developments regarding PFAS reporting requirements at the federal and state level. Stay tuned for updates!
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