Perfluoroalkyl and Polyfluoroalkyl Substances PFAS are dangerous synthetic organofluorine chemical compounds
Vol. 1476 | 14 May 2025

EPA delays PFAS reporting under TSCA to April 2026, citing system development and possible rule changes; public comments accepted until June 2025.

Introduction

On May 13, 2025, the US Environmental Protection Agency (EPA) published an interim final rule in the Federal Register, officially postponing the start of the PFAS reporting period under the Toxic Substances Control Act (TSCA). This marks the second delay in the implementation of this reporting requirement, originally finalized in October 2023.

Why the Delay?

The EPA cited the ongoing development and testing of its electronic reporting system as the reason for the extension. Additionally, the Agency has signaled that it may reopen portions of the rule for further public comment, suggesting that further revisions to reporting requirements may be on the horizon.

Updated PFAS Reporting Timeline

  • Reporting Start Date: April 13, 2026
  • Reporting End Date: October 13, 2026
  • Extended Deadline: April 13, 2027 (for small manufacturers/importers reporting solely for articles)

Background

The PFAS reporting rule requires manufacturers and importers (including those dealing with articles) to report detailed information about PFAS substances used between 2011 and 2022. The rule is designed to improve the EPA’s understanding of the scope and use of PFAS across industries, informing future risk assessments and regulatory actions.

Public Comment Opportunity

The EPA is currently accepting public comments on the interim final rule.

This is a critical opportunity for stakeholders to provide feedback and help shape future regulatory obligations. We encourage companies particularly those in industries with PFAS exposure to collaborate with relevant trade associations and submit comments where applicable.

Next Steps

Companies should continue to monitor developments related to PFAS reporting under TSCA and evaluate potential impacts on their operations and supply chains. For questions or assistance in interpreting how this rule may affect your business, please don’t hesitate to contact us.

If you have any questions, please contact:

Pankaj Sarda's profile pic
Pankajkumar Sarda

Director Technical Services, Global Softlines

Pankaj Sarda has nearly 20 years of experience in consumer goods, focusing on regulatory compliance, product testing, and chemical management. He advises on product safety and regulatory changes, serving as a member of the Apparel and Footwear Association’s RSL Working Group. Pankaj holds degrees in Material Science, Business Administration, Textile Chemistry, and Manufacturing from the University of Massachusetts and the Textile & Engineering Institute in India.

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