EPA Further Delays PFAS Reporting Deadline Under TSCA

Vol. 1476 | 14 May 2025
EPA delays PFAS reporting under TSCA to April 2026, citing system development and possible rule changes; public comments accepted until June 2025.
Introduction
On May 13, 2025, the US Environmental Protection Agency (EPA) published an interim final rule in the Federal Register, officially postponing the start of the PFAS reporting period under the Toxic Substances Control Act (TSCA). This marks the second delay in the implementation of this reporting requirement, originally finalized in October 2023.
Why the Delay?
The EPA cited the ongoing development and testing of its electronic reporting system as the reason for the extension. Additionally, the Agency has signaled that it may reopen portions of the rule for further public comment, suggesting that further revisions to reporting requirements may be on the horizon.
Updated PFAS Reporting Timeline
- Reporting Start Date: April 13, 2026
- Reporting End Date: October 13, 2026
- Extended Deadline: April 13, 2027 (for small manufacturers/importers reporting solely for articles)
Background
The PFAS reporting rule requires manufacturers and importers (including those dealing with articles) to report detailed information about PFAS substances used between 2011 and 2022. The rule is designed to improve the EPA’s understanding of the scope and use of PFAS across industries, informing future risk assessments and regulatory actions.
Public Comment Opportunity
The EPA is currently accepting public comments on the interim final rule.
- Deadline to Submit Comments: June 12, 2025
This is a critical opportunity for stakeholders to provide feedback and help shape future regulatory obligations. We encourage companies particularly those in industries with PFAS exposure to collaborate with relevant trade associations and submit comments where applicable.
Next Steps
Companies should continue to monitor developments related to PFAS reporting under TSCA and evaluate potential impacts on their operations and supply chains. For questions or assistance in interpreting how this rule may affect your business, please don’t hesitate to contact us.