SG 067/25
US Environmental Protection Agency (EPA) pushes back the submission period under the TSCA PFAS Reporting Rule by nine months to allow modifications and the full development of reporting software.
On September 28, 2023, the EPA signed into effect the ‘Toxic Substances Control Act Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances’ (‘TSCA PFAS Reporting Rule’, SG 133/23). This rule requires businesses that have manufactured or imported PFAS, including PFAS containing articles, for commercial purposes between January 1, 2011, and December 31, 2022, to report designated PFAS compounds to the EPA. The original submission period under the law was from November 12, 2024, to May 8, 2025, with an additional six months for small businesses.
On September 5, 2024, the EPA issued a direct final rule (DFR) which delayed reporting time frames by eight months (SG 142/24). The final rule pushed back the general submission period from July 11, 2025, to January 11, 2026.
On May 12, 2025, the EPA announced a second delay to the reporting window. Per the interim final rule, the start of the submission period has been pushed back by another nine months. Per the agency’s announcement, this additional delay will, “help to develop and test the software being used to collect the data from manufacturers.”
While the delay to the submission period is effective immediately, the EPA will accept public comments on the change until June 12, 2025.
Table 1 summarizes the updated submission windows.
| New submission period under interim final rule issued on May 12, 2025 | |||
| General | April 13, 2026 – October 13, 2026 | ||
| Small manufacturers1 reporting exclusively as article importers | April 13, 2026 – April 13, 2027 | ||
| 1 As defined under 40 CFR 704.3 | |||
Furthermore, the agency is considering a separate action to reopen other aspects of the rule for public comment.
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