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ARTICLE · 30 APRIL 2026

EPA Again Delays TSCA PFAS Reporting With New Exemptions And Revised Deadlines

Kelley Drye & Warren LLP
Kelley Drye & Warren LLP
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Kelley Drye & Warren LLP

Kelley Drye & Warren LLP

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The Environmental Protection Agency (EPA or Agency) has announced, via a pre-publication Federal Register Notice, that it intends to delay the submission period for manufacturers to report on their per- and polyfluoroalkyl (PFAS) uses, extending the start date of the six-month reporting period from April 13, 2026, to either (1) 60 days after the effective date of the upcoming rule aimed at revising the program, or (2) January 31, 2027—whichever is earlier.

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The Environmental Protection Agency (EPA or Agency) has announced, via a pre-publication Federal Register Notice, that it intends to delay the submission period for manufacturers to report on their per- and polyfluoroalkyl (PFAS) uses, extending the start date of the six-month reporting period from April 13, 2026, to either (1) 60 days after the effective date of the upcoming rule aimed at revising the program, or (2) January 31, 2027—whichever is earlier.

By way of a refresher, the 2023 PFAS reporting rule, mandated by 2020 defense legislation, requires any entity that manufactured or imported PFAS between 2011 and 2022 to report extensive information under Section 8(a) of the Toxic Substances Control Act (TSCA). Covered entities initially included all manufacturers and importers of products for commercial purposes if those entities knew, or could reasonably ascertain information, that their products contain PFAS in any amount. The rule’s original scope included no threshold for

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