EPA Further Extends Dates for PFAS Reporting under TSCA

By John Kowalski, regulatory affairs lead, Supply Chain Team, UL Solutions

On Oct. 11, 2023, the U.S. Environmental Protection Agency (EPA or Agency) published a final reporting and recordkeeping rule for Per- and polyfluoroalkyl substances (PFAS) under Section 8(a)(7) of the Toxic Substances Control Act (TSCA). The Agency subsequently published a direct final rule on Sept. 5, 2024 to extend the reporting period for the PFAS reporting rule. See our Regulatory Update for a summary of that rule.

On May 13, 2025, EPA published an interim final rule to further extend the reporting period for the PFAS reporting rule. The reporting period was scheduled to begin on July 11, 2025. But, the interim final rule delays the beginning of the reporting period until Apr. 2026. More specifically, it changes the data submission period to open on Apr. 13, 2026, with corresponding changes to the end of the submission period.

Under the interim final rule, most reporters will be required to complete all reporting by Oct. 13, 2026. However, small businesses that are subject to reporting based solely upon the importation of PFAS-containing articles will have until Apr. 13, 2027 to submit reports.

The Agency also stated, in the preamble to the interim final rule, that it “is separately considering reopening certain aspects of the rule to public comment.” Furthermore, it stated that “The delayed reporting date ensures that EPA has adequate time to consider the public comments and propose and finalize any modifications to the rule before the submission period begins.” Finally, the interim final rule took effect immediately upon publication in the Federal Register.

Reference

Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Change to Submission Period; 91 Fed. Reg. 20236; May 13, 2025