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ARTICLE · 16 MAY 2025

PFAS Reporting Rule Deadlines Extended – And More Changes To Come

Beveridge & Diamond, P.C.
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The U.S. Environmental Protection Agency (EPA) published an interim final rule on May 13, 2025, extending the reporting deadlines for its Per- and polyfluoroalkyl substances (PFAS) Reporting Rule...

United StatesEnergy and Natural Resources
Mark N. Duvall
Mark N. Duvall
Ryan J. Carra
Ryan J. Carra
Emily E. Schwartz
Emily E. Schwartz

The U.S. Environmental Protection Agency (EPA) published an interim final rule on May 13, 2025, extending the reporting deadlines for its Per- and polyfluoroalkyl substances (PFAS) Reporting Rule, 40 C.F.R. Part 705, which mandates submission of data on PFAS. EPA also disclosed that it will soon publish a notice of proposed rulemaking to address other aspects of the rule. The new deadlines appear in amended 40 C.F.R. § 705.20. Most reports on PFAS as chemicals are now due by October 13, 2026. Reports on PFAS in imported articles by small manufacturers are now due by April 13, 2027.

Background

EPA finalized the PFAS Reporting Rule on October 11, 2023, under Section 8(a)(7) of the Toxic Substances Control Act (TSCA), as amended by Section 7351 of the National Defense Authorization Act for Fiscal Year 2020, Pub. L. 116-92. This rule obligates any entity that manufactured or imported PFAS from 2011 through 2022 to submit a one-time report to EPA regarding

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