EPA Delays TSCA Section 8(a)(7) PFAS Reporting Start Date

By Chelsea Anderson, Senior Regulatory Specialist, Supply Chain Team, UL Solutions

The Toxic Substances Control Act (TSCA) Section 8(a)(7) Per- and Polyfluoroalkyl Substances (PFAS) Reporting Rule was finalized on October 11, 2023. The rule imposed a one time reporting obligation on any entity that has manufactured or imported, for commercial purposes since 2011, a PFAS containing chemical substance, mixture, or article. The rule also provided a defined molecular structure for PFAS. Please see UL’s Regulatory Update for more information.

The initial PFAS reporting period was set to begin on November 12, 2024, but has been delayed multiple times since. In the November 13, 2025, edition of the Federal Register, the Environmental Protection Agency (EPA or Agency) also proposed changes to other aspects of the reporting rule including exemptions for 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. See UL’s Regulatory Update for a summary of that rule.

The most recent final rule, published on April 13, 2026, postpones the start of the reporting period in order to provide the EPA with additional time to review and address public comments. It states that “the submission period for the PFAS Reporting Rule will begin, on January 31, 2027, or 60 days following the effective date of a forthcoming final rule on the substantiative requirements of the PFAS Reporting Rule, whichever is earlier.” In other words, January 31, 2027 serves as the backstop start date for PFAS reporting, unless EPA finalizes another rule earlier, in which case reporting would begin 60 days after that rule takes effect. The Agency expects to finalize a future rule that will replace the fallback start date and remove it altogether, “regardless of whether the EPA ultimately decides to finalize all, some, or none of the proposed substantive revisions to the PFAS Reporting Rule.”

Reference

Modification to the Start of the Submission Period for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Reporting and Recordkeeping Under TSCA 8(a)(7); Final Rule; 91 Fed. Reg. 18786; April 13, 2026.