Tech Watch: EPA Final Rule | TSCA Section 8(a)(7) PFAS Reporting Submission Period Delayed

EPA Final Rule: TSCA Section 8(a)(7) PFAS Reporting Submission Period Delayed

Effective 13 April 2026, the U.S. Environmental Protection Agency (EPA) published a final rule modifying the start of the data submission period under the Toxic Substances Control Act (TSCA) Section 8(a)(7) PFAS Reporting and Recordkeeping Rule. The new submission period will begin on 31 January 2027, or 60 days after EPA publishes a forthcoming final rule on the substantive requirements of the PFAS Reporting Rule, whichever date is earlier.

This is the third extension of the original November 2024 reporting deadline. While no data submission is immediately required, entities within scope must continue internal due diligence, supply chain data gathering, and readiness preparation.

Substantive Revisions Remain Pending

EPA proposed significant substantive amendments on 13 November 2025 (90 FR 50923). These include potential exemptions for:

De minimis concentrations (proposed threshold: 0.1% by weight)
Imported articles containing PFAS
PFAS generated as byproducts
PFAS present as impurities
PFAS used exclusively in research and development (R&D)
Non-isolated intermediates

EPA received numerous comments on this proposal. The comment period closed on 29 December 2025. The agency must review, respond, and finalise before triggering the 60-day countdown.

Duration of Reporting Window Unchanged

This final rule (91 FR 18786) addresses only the start of the submission period. The length of the reporting window remains as codified:

Standard reporters: 6-month window from the new start date
Small manufacturers of article import only: 12-month window from the new start date

For questions and additional information, please contact:
Dr. Pratik Ichhaporia (pratikichhaporia@eurofinsus.com, +1-669-837-2257) or David Hong (David.Hong@cpt.eurofinscn.com).

Source:
Federal Register Notice: https://www.govinfo.gov/content/pkg/FR-2026-04-13/pdf/2026-07062.pdf