U.S. EPA Proposes Changes to PFAS Reporting under TSCA

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

On Nov. 13, 2025, the U.S. Environmental Protection Agency (EPA or the agency) published a Proposed Rule in the Federal Register to revise the reporting and recordkeeping rule for Per- and polyfluoroalkyl substances (PFAS) under Section 8(a)(7) of the Toxic Substances Control Act (TSCA). The original rule, published in the Oct. 11, 2023 edition of the Federal Register, established a one-time reporting requirement and recordkeeping requirements for manufacturers (including importers) of PFAS between the years 2011-2022. Please see UL Solutions’ previous article for more information on that rule.

According to the EPA, the proposed changes include exemptions and modifications aimed at “reducing regulatory reporting burdens and providing greater regulatory certainty to industry, resulting in a net reduction in cost while ensuring that EPA receives the PFAS data that are most relevant to the agency.” The proposed exemptions are as follows:

• 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 EPA also proposes postponing the submission period again, from Apr. 13 - Oct. 13, 2026 (with Apr. 13, 2027 for small manufacturers reporting solely as article importers), to begin 2 months after the effective date of the final rule, and to remain open for 3 months (instead of 6 months). EPA is also proposing to update the names used for specific consumer and commercial product categories in order to help clarify existing requirements. Please see Table 1 on page 50931 of the proposed rule for the updated names and descriptions.

The EPA is requesting feedback on certain aspects of the proposed rule for 45 days (by Dec. 29, 2025) in docket #EPA-HQ-OPPT-2020-0549 on www.regulations.gov.

Reference

Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Revision to Regulation; 90 Fed. Reg. 50923; November 13, 2025