EPA TSCA Section 8(a)(7) PFAS Reporting Requirements – Key Updates

The U.S. Environmental Protection Agency (EPA) has finalized reporting and recordkeeping requirements for Per- and Polyfluoroalkyl Substances (PFAS) under the Toxic Substances Control Act (TSCA). Any person who manufactures (including imports) or has manufactured PFAS or PFAS-containing articles since January 1, 2011, must electronically report information regarding PFAS uses, production volumes, disposal, exposures, and hazards to EPA through the Central Data Exchange (CDX).

Current Reporting Timeline

The reporting period has been extended multiple times due to EPA resource constraints and software development delays. Submissions are now due by October 13, 2026, for most manufacturers. Small businesses reporting data solely on importing PFAS-contained articles have until April 13, 2027, to submit reports.

What Must Be Reported

Manufacturers must provide data on chemical identity and molecular structure, categories of use, total amounts manufactured or processed, byproducts, existing environmental and health effects information, worker exposure numbers and duration, and disposal methods.

November 2025 Proposed Exemptions

Among the key proposed updates, EPA recently proposed exemptions to reduce unnecessary or duplicative reporting requirements for:

• PFAS manufactured or 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

Comments on these proposed changes are being accepted for 45 days on www.regulations.gov