EPA Proposes Important Revisions To Its PFAS Reporting Regulations

What You Need to Know

• Key takeaway #1 EPA's proposed amendments to the current regulations would profoundly scale back on the scope of companies' PFAS reporting obligations.
• Key takeaway #2 Perhaps most importantly, the proposed regulations would eliminate reporting for manufactured articles.
• Key takeaway #3 It is important to recognize that even if the proposed amendments to EPA's PFAS reporting rules are finalized, companies that manufacture or import products containing PFAS, including manufactured articles made with PFAS, may still be subject to state PFAS reporting obligations (e.g., in Minnesota).

On November 10, 2025, the U.S. Environmental Protection Agency (EPA) released proposed regulations that, if adopted, would substantially alter the reporting obligations of companies that manufacture or import products containing per- or polyfluoroalkyl substances (PFAS). The proposed regulations would significantly reduce reporting burdens by exempting