On April 8, 2026, Lee Zeldin, Administrator of the U.S. Environmental Protection Agency (EPA), signed the final rule, further postponing the initiation date for per- and polyfluoroalkyl substances (PFAS) data reporting obligations under Section 8(a)(7) of the Toxic Substances Control Act (TSCA) to January 31, 2027. This marks the third extension since EPA established this rule in 2023.
Background
- October 11, 2023: EPA finalized the PFAS reporting rule, requiring entities that manufactured (including imported) PFAS or PFAS-containing articles since January 1, 2011, to report detailed information to EPA
- Originally scheduled submission period: Beginning November 12, 2024
- First extension: September 5, 2024 – delayed to July 11, 2025 due to delays in developing the electronic reporting system (CDX)
- Second extension: May 13, 2025 – delayed to April 13, 2026 due to continued IT development delays
Key Modifications in This Final Rule
|
Item |
Original Requirement |
New Requirement |
|
Submission period start date for standard reporters |
April 13, 2026 |
January 31, 2027, or 60 days after the date specified in 40 CFR 705.20(c), whichever is earlier |
|
Submission period start date for small article importers |
April 13, 2026 |
January 31, 2027, or 60 days after the date specified in 40 CFR 705.20(c), whichever is earlier |
|
Duration of submission period |
6 months (until October 13, 2026) |
6 months (standard reporters) / 12 months (small article importers) |
Important Notes
- This rule adjustment only modifies the submission period start date and does not involve the submission period end date or other substantive modifications
- EPA plans to issue a subsequent final rule before January 31, 2027, to address other issues raised in the November 2025 proposal (such as exemption clauses, etc.)
- The rule adopts a severability clause design: if the "60-day period" is overturned in judicial review, the fallback date of January 31, 2027 remains valid; conversely, the same applies
