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ARTICLE · 02 JULY 2021

EPA Proposes New PFAS Requirements Under TSCA

Bryan Cave Leighton Paisner
Bryan Cave Leighton Paisner
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Bryan Cave Leighton Paisner

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The Environmental Protection Agency ("EPA") has announced it is taking three actions with respect to per- and polyfluoroalkyl substances ("PFAS") under the

United StatesEnvironment
Brandon Neuschafer
Brandon Neuschafer
Thomas S. Lee
Thomas S. Lee
John R. Kindschuh
John R. Kindschuh

Summary

The Environmental Protection Agency ("EPA") has announced it is taking three actions with respect to per- and polyfluoroalkyl substances ("PFAS") under the Toxic Substances Control Act ("TSCA"): (1) proposing a rule that is designed to enact reporting requirements for PFAS products that are manufactured or imported in the United States; (2) eliminating guidance that EPA asserts weakened the Significant New Use Rule ("SNUR") regarding long-chain PFAS; and (3) publishing a final rule that incorporates three additional PFAS substances into the Toxics Release Inventory ("TRI").

Recordkeeping and Reporting Requirements

EPA's proposed recordkeeping requirements, published on June 10, 2021, would require that certain businesses to electronically report information to EPA regarding any PFAS substances (see pages 18-21 of the linked proposal for the complete list).  Significantly, the definition of "PFAS substances" is "any chemical substance or mixture

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