EPA Finalizes Stringent PFAS Reporting Guidelines for Chemical Manufacturers

EPA Strengthens PFAS Reporting Requirements

The U.S. Environmental Protection Agency (EPA) is strengthening oversight of per- and polyfluoroalkyl substances (PFAS) through reporting and recordkeeping requirements under Section 8(a)(7) of the Toxic Substances Control Act (TSCA).

The original PFAS reporting rule was finalized in October 2023 and requires companies that manufactured or imported PFAS during any year from 2011 through 2022 to provide information to EPA. The required information covers chemical identity, uses, production volumes, disposal, byproducts, worker exposure, and environmental and health effects. (US EPA)

As of 2026, EPA has continued modifying the implementation timeline and scope of the reporting program. In April 2026, EPA finalized another change moving the beginning of the reporting period to 60 days after the effective date of a forthcoming revision to the PFAS reporting rule. EPA said it was reviewing the rule and its November 2025 proposed changes before issuing a further final rule. (US EPA)

What Companies Need to Report

The TSCA Section 8(a)(7) rule is designed to give EPA a broader picture of how PFAS have been manufactured and used in the United States.

Companies covered by the rule may need to provide information including:

• Chemical identity and molecular structure

• Categories and types of PFAS uses

• Production and processing volumes

• Manufacturing and processing activities

• PFAS byproducts

• Disposal practices

• Worker exposure information

• Existing environmental and health effects information

EPA requires covered entities to submit the information electronically through its Central Data Exchange (CDX) system. (US EPA)

Who Could Be Affected?

The reporting requirements apply broadly to businesses that manufactured, including imported, PFAS during the specified historical period. The rule also addresses PFAS contained in imported articles.

However, EPA proposed changes in November 2025 that would introduce several exemptions and modifications. These proposals include potential exclusions for PFAS present in mixtures or products at concentrations of 0.1% or lower, imported articles, certain byproducts, impurities, research and development chemicals, and non-isolated intermediates. (US EPA)

Because these provisions have been subject to regulatory changes, companies should verify the latest EPA requirements rather than relying solely on the original 2023 rule.

Reporting Timeline Has Changed

The implementation schedule for the PFAS reporting rule has undergone several changes.

In May 2025, EPA extended the reporting period, setting October 13, 2026 as the submission deadline for most manufacturers under the then-current schedule. Small businesses reporting solely on importing PFAS-containing articles were given until April 13, 2027. (US EPA)

In April 2026, however, EPA announced another change. The agency stated that the reporting period would begin 60 days after the effective date of its forthcoming revision to the PFAS 8(a)(7) rule. EPA indicated that it planned to issue the revised final rule later in 2026. (US EPA)

This means chemical manufacturers and importers should continue monitoring EPA announcements for the operative reporting start date and any changes to the scope of covered substances and activities.

Growing PFAS Reporting Across EPA Programs

The TSCA reporting rule is separate from PFAS reporting under the Toxics Release Inventory (TRI).

EPA has continued adding PFAS to TRI. In February 2026, EPA finalized the addition of sodium perfluorohexanesulfonate (PFHxS-Na) to the TRI list. Facilities in covered industries must track relevant use and releases beginning with the 2026 reporting year, with reports due July 1, 2027. (US EPA)

The development demonstrates that companies may face PFAS-related reporting obligations under more than one federal environmental program, depending on their activities and the chemicals involved.

Why the Requirements Matter for Chemical Manufacturers

PFAS are used across numerous industrial and commercial applications because of properties such as chemical resistance, thermal stability and resistance to water and oil. Their persistence has also resulted in increased regulatory attention.

For manufacturers and importers, expanded reporting requirements can create additional responsibilities involving data collection, historical record review and supply-chain information management.

Companies may need to locate information covering PFAS manufactured or imported years ago, determine whether substances fall within the applicable PFAS definition, and compile information from different internal departments and suppliers.

What Chemical Companies Should Do

Businesses potentially affected by the TSCA PFAS reporting requirements should consider taking several practical steps:

1. Review historical manufacturing and import records for the 2011–2022 period.

2. Identify PFAS substances and mixtures that may fall within the applicable reporting requirements.

3. Collect production, use and disposal information from internal records.

4. Review available exposure and environmental or health information.

5. Monitor EPA updates concerning the revised reporting rule and submission dates.

6. Review exemptions carefully before determining whether a substance or activity is outside the reporting scope.

7. Prepare for electronic submission through CDX if reporting is required.

Maintaining organized chemical inventories and historical records can make it easier for companies to respond when regulatory reporting obligations arise.

A Continuing Shift Toward Greater PFAS Transparency

EPA's PFAS reporting program is intended to improve the federal government's understanding of where PFAS have been manufactured and used and what information is available concerning their potential environmental and health effects. The 2023 rule was designed to create a comprehensive dataset covering PFAS manufacturing and use during the 2011–2022 period. (US EPA)

At the same time, the regulatory framework remains subject to changes. EPA's 2025 proposal and 2026 actions show that the agency is continuing to modify how the reporting program will be implemented.

For chemical manufacturers, importers and other potentially affected businesses, keeping track of the latest TSCA requirements will therefore be essential for determining reporting obligations and preparing accurate regulatory submissions.

Sources

1. U.S. EPA – TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for PFAS
   EPA PFAS Reporting and Recordkeeping Requirements

2. U.S. EPA – Update on Reporting Deadline for TSCA PFAS Reporting Rule, April 2026
   EPA Reporting Deadline Update

3. U.S. EPA – EPA Proposes Changes to PFAS Reporting Requirements, November 2025
   EPA PFAS Reporting Proposal

4. U.S. EPA – EPA Expands Toxic Chemical Reporting for PFHxS-Na, February 2026
   EPA PFHxS-Na TRI Update

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