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ARTICLE · 17 OCTOBER 2023

Broad EPA PFAS Rule To Have Significant Impact For Manufacturers

Reinhart, Boerner, Van Deuren SC
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On September 28, 2023, the U.S. Environmental Protection Agency (EPA) issued its final rule under the Toxic Substances Control Act (TCSA) mandating that businesses that have manufactured...

United StatesEnvironment
Guy Temple
Guy Temple
Danielle E. Marocchi
Danielle E. Marocchi
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On September 28, 2023, the U.S. Environmental Protection Agency (EPA) issued its final rule under the Toxic Substances Control Act (TCSA) mandating that businesses that have manufactured or imported PFAS chemicals—including importers of articles containing any PFAS—report extensive information on the chemicals going back to 2011.

Companies have just 18 months from the rule's November 13, 2023 effective date to report 10+ years of data.Businesses will need to take steps now to review their operations, product categories and supply chains to gather information on PFAS usage.

What Does the Rule Cover?

The EPA is required under Section 8(a)(7) of TCSA to collect information on PFAS manufactured and imported for commercial purposes. The rule therefore requires companies that have manufactured PFAS in any year since January 1, 2011, to electronically report certain information to the EPA, including:

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