EPA’s PFAS Dragnet: What Companies Need to Know About PFAS Reporting Under TSCA Section 8(a)(7)

December 13, 2024

Read the full article by Louise Dyble, Jeffrey J. Parker, and Olivier F. Theard (The National Law Review)

"Compliance with EPA’s Rule for Reporting and Recordkeeping Requirements for per- and polyfluoroalkyl substances (PFAS) under the Toxic Substances Control Act (TSCA) Section 8(a)(7) will demand the attention and resources of companies that have manufactured or imported PFAS, or articles containing PFAS, since 2011.

The Rule requires a one-time report with information on the nature, quantity, byproducts, uses, releases, or disposal of PFAS chemicals dating back to January 1, 2011. Companies must conduct an investigation and submit all “reasonably ascertainable” information on all of the products that they have manufactured or imported since that date.

Companies should be preparing now to meet these requirements. The window for reporting is July 11, 2025 through January 11, 2026 for most companies, but small businesses that only import articles with PFAS have an additional six months to report."