EPA Further Delays TSCA PFAS Reporting Period: Key Considerations for Companies Preparing to Report

22 May 2026

The Environmental Protection Agency (EPA) has finalized a rule further delaying the start of the Toxic Substances Control Act (TSCA) Section 8(a)(7) reporting period for per- and polyfluoroalkyl substances (PFAS). The reporting window is now expected to begin January 31, 2027, or 60 days after the effective date of EPA's forthcoming final revisions to the TSCA PFAS reporting  rule, whichever is earlier. EPA is continuing to evaluate proposed changes to the scope of the TSCA PFAS reporting rule, including potential exemptions for certain imported articles, de minimis concentrations, byproducts, impurities, research and development (R&D) chemicals, and non-isolated intermediates. The final scope of the reporting obligations remains uncertain, but this alert outlines a few key considerations for entities that are preparing to report.

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