EPA Announces Proposed Delay for TSCA 8(a)(7) PFAS Reporting Requirements

The U.S. Environmental Protection Agency (EPA) has announced plans to delay the reporting window for the TSCA Section 8(a)(7) PFAS Recordkeeping and Reporting Rule. This significant change provides companies with additional time to prepare for compliance with these extensive reporting requirements.

According to the EPA's proposal, the general reporting window will now begin on April 13, 2026 and close on October 13, 2026, shifting from the original July 2025 start date. For small manufacturers reporting solely as article importers, an extended timeline applies, with their reporting window opening on April 13, 2027.

We will continue to monitor updates from the EPA and will keep you informed of any further developments.

Preparing for Compliance with CDX
While the reporting deadlines have been extended, the Compliance Data eXchange (CDX) platform continues to offer comprehensive support for organizations preparing for TSCA 8(a)(7) PFAS compliance. Companies are encouraged to use this additional time to:

• Collect PFAS data throughout the supply chain using CDX's supplier communication tools
• Analyze Material Data Sheets (MDS) to identify in-scope PFAS substances in materials and articles
• Request and manage PFAS declaration statements from suppliers to strengthen due diligence efforts

About the TSCA 8(a)(7) PFAS Rule
The TSCA Section 8(a)(7) PFAS Recordkeeping and Reporting Rule requires manufacturers (including importers) to report information about PFAS manufactured or imported since January 1, 2011, including information on uses, production volumes, disposal, exposures, and hazards.

Taking Proactive Steps
We recommend using this additional preparation time to thoroughly assess your obligations, engage with your supply chain, and organize your data. Organizations can use CDX to begin mapping their supply chains, identifying potential PFAS-containing materials, and establishing robust data collection processes well ahead of the reporting deadlines.