Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 17 NOVEMBER 2025

EPA Proposes Significant Amendments To PFAS Reporting Rule

Arnold & Porter
Arnold & Porter
Contributor
Arnold & Porter

Arnold & Porter

With over 1,000 lawyers across 16 offices worldwide, Arnold & Porter is renowned for its...

View firm profile
Explore more from Arnold & Porter

The U.S. Environmental Protection Agency (EPA) has released a pre-publication edition of its much-anticipated proposal to amend the Toxic Substances Control Act (TSCA)...

United StatesEnvironment
Lawrence E. Culleen
Lawrence E. Culleen
Katrina R. Umstead
Katrina R. Umstead
Author LinkedIn connections

The U.S. Environmental Protection Agency (EPA) has released a pre-publication edition of its much-anticipated proposal to amend the Toxic Substances Control Act (TSCA) reporting and recordkeeping regulation for per- and polyfluoroalkyl substances (PFAS). The term PFAS, as defined in the current rule, could include potentially thousands of individual chemical substances. The amendments proposed could substantially reduce the reporting burdens imposed by the 2023 edition codified during the Biden administration.

In October 2023, EPA finalized its rule requiring manufacturers and importers to report detailed information on PFAS domestically manufactured or imported between 2011 and the end of 2022. The PFAS reporting rule implements a provision of the National Defense Authorization Act for Fiscal Year 2020, which added TSCA section 8(a)(7).1 As currently codified, the rule established the first comprehensive PFAS reporting program under TSCA, capturing PFAS

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

Texas Governor Abbott Directs TCEQ To Freeze All Data Center Permits In A Whole-of-Government Action

Governor Greg Abbott has ordered the Texas Commission on Environmental Quality to immediately halt all environmental permits for data center projects, expanding a statewide regulatory freeze that now encompasses power, water, and environmental approvals. This directive establishes strict operational mandates requiring data centers to fully fund infrastructure costs, report all resource consumption...
United StatesEnvironment
Foley & Lardner LLP
Foley & Lardner LLP
Article

Governor Abbott Orders TCEQ To Pause All Permit Issuance For Data Center Projects

Governor Abbott has ordered Texas environmental regulators to halt all data center permit issuance until grid operators complete a comprehensive audit in mid-December 2026. The sweeping directive affects not only grid-connected facilities but also fully islanded data centers relying on behind-the-meter generation, creating uncertainty for developers and their contractual obligations.
United StatesEnvironment
Bracewell LLP
Bracewell LLP
Article

California SB 253: CARB Sets Nov. 10, 2026, Deadline For Scope 1 And Scope 2 Emissions Reports

California's Climate Corporate Data Accountability Act (SB 253) establishes a November 10, 2026 deadline for Scope 1 and Scope 2 greenhouse gas emissions reporting, affecting U.S.-formed entities with over $1 billion in revenue that meet California's "doing business" test—regardless of physical presence in the state. The law carries penalties up to $500,000 per reporting year for non-compliance, with mandatory program fees and future Scope 3 reporting requirements on the horizon.
United StatesEnvironment
Greenberg Traurig
Greenberg Traurig
Article

Texas Governor Directs A Halt On Data Center Permitting With State Agency Audits

Texas Governor Greg Abbott has directed state agencies to halt all data center permits until comprehensive audits assess the projects' impacts on electric infrastructure, residential ratepayers, and water resources. The directive requires data centers to fully fund necessary electric infrastructure and comply with enhanced reporting requirements, while the governor signals potential legislative action to codify new protections and phase out certain tax incentives.
United StatesEnvironment
Greenberg Traurig
Greenberg Traurig
Article

Governor Signs Seven Data Center Bills Addressing Energy And Noise Reporting, Water Use, Labor Standards, Electricity Rates, And CEQA Review

California has enacted seven unprecedented bills targeting data center development, imposing sweeping new requirements for energy reporting, water consumption assessments, labor standards, and electricity rate structures. These laws fundamentally reshape the regulatory landscape for data centers, requiring detailed disclosures at multiple project stages while prohibiting categorical CEQA exemptions and establishing new interconnection rules that shift infrastructure costs directly to developers.
United StatesEnvironment
Cox, Castle & Nicholson
Cox, Castle & Nicholson
Article

The Chemical Compound — Q3 2026

This quarterly newsletter examines critical developments in chemical regulatory law, covering litigation outcomes that reshape EPA's authority under TSCA, landmark Supreme Court decisions on pesticide labeling preemption, and emerging state and international frameworks governing PFAS and other chemicals of concern. The edition analyzes how recent Fifth Circuit rulings on methylene chloride regulations may fundamentally alter EPA's approach to risk evaluations and management rules across its entire existing
United StatesEnvironment
Arnold & Porter
Arnold & Porter
Article

CEQA Reform Qualifies For The Ballot: What To Know About The Building An Affordable California Act

California voters will decide on Proposition 45 this November, a sweeping initiative that would fundamentally reshape environmental review for housing, infrastructure, and other essential projects across the state. The Building an Affordable California Act promises faster approvals and limited judicial challenges, but faces organized opposition from labor unions and environmental groups. Will this measure succeed in streamlining development, or does it go too far in curtailing environmental protections?
United StatesEnvironment
Rutan & Tucker LLP
Rutan & Tucker LLP
Article

New EU PFHxA Limits Take Effect Amid Expanding PFAS Rules For Apparel And Textiles

Beginning October 10, 2026, the European Union will restrict certain concentrations of PFHxA and related substances in clothing and footwear, marking a significant expansion of PFAS regulations affecting the apparel and textile industry. Companies face a complex patchwork of requirements as France, Denmark, and multiple U.S. states implement their own PFAS restrictions with varying scopes, thresholds, and compliance approaches. Navigating these divergent regulations requires careful supply chain evaluation
European UnionEnvironment
Beveridge & Diamond, P.C.
Beveridge & Diamond, P.C.
Article

Root Causes Updates And Insights On Quality And Inspections

This issue covers U.S. Food and Drug Administration (FDA), Drug Enforcement Administration (DEA), and U.S. Health and Human Services (HHS) developments spanning inspections, enforcement, transparency, and emerging product categories. FDA’s drug center and inspections office have updated their framework for coordinating facility evaluations and inspections (ConOps 2.0), and FDA has changed how it processes post-approval facility withdrawals for New Drug Applications (NDAs) and Abbreviated New Drug Applications (ANDAs).
United StatesFood, Drugs, Healthcare, Life Sciences
Arnold & Porter
Arnold & Porter
Article

The Chemical Compound — Q3 2026

This quarterly newsletter examines critical developments in chemical regulatory law, covering litigation outcomes that reshape EPA's authority under TSCA, landmark Supreme Court decisions on pesticide labeling preemption, and emerging state and international frameworks governing PFAS and other chemicals of concern. The edition analyzes how recent Fifth Circuit rulings on methylene chloride regulations may fundamentally alter EPA's approach to risk evaluations and management rules across its entire existing
United StatesEnvironment
Arnold & Porter
Arnold & Porter
Article

Pseudonymised, Not Anonymous: What The Italian Garante’s €7 Million IQVIA Fine Means For Health Data

The Italian data protection authority fined IQVIA Solutions Italy €7 million for treating patient records as anonymous when they were actually pseudonymised personal data subject to GDPR. This decision demonstrates regulators' strict interpretation of what constitutes personal data, even as the EU considers narrowing this definition through the Digital Omnibus reforms.
GlobalPrivacy
Arnold & Porter
Arnold & Porter
Article

FDA Issues Prescription Drug Use-Related Software Guidance After A Several-Year Delay

The FDA has finalized guidance on Prescription Drug Use-Related Software (PDURS), establishing how drug labeling authorities apply to software disseminated by pharmaceutical sponsors. This regulatory framework distinguishes between software essential to safe drug use and promotional applications, while clarifying submission requirements and clinical evidence standards for including software functions in FDA-approved prescribing information.
United StatesFood, Drugs, Healthcare, Life Sciences
Arnold & Porter
Arnold & Porter
Article

Generative AI Is Reshaping The Defense Of Complex Litigation

Generative AI is transforming litigation defense by enabling in-house legal teams to manage costs and complexity more effectively across the entire case lifecycle. From early research and drafting through expert witness strategy and trial preparation, AI tools are helping defense teams work faster and more consistently. How are these technologies reshaping the way sophisticated counsel approaches multidistrict litigation, mass torts, and large-scale document management?
United StatesMedia, Telecoms, IT, Entertainment
Arnold & Porter
Arnold & Porter
Article

The FCC’s Next Move On Supply Chain Security: What Manufacturers Need To Know

The Federal Communications Commission has proposed sweeping changes to its equipment authorization program that would reorganize security restrictions around where devices are manufactured rather than who makes them. These new measures could fundamentally reshape how communications equipment—from smartphones to data center hardware—enters the U.S. market, with significant implications for manufacturers relying on foreign production.
United StatesGovernment, Public Sector
Arnold & Porter
Arnold & Porter
Article

A Tale Of Two Sanctions Programs: U.S. Delivers Syria Relief While Launching Latest Economic Campaign Against Iran

The U.S. government simultaneously extended sanctions relief to Syria while launching an aggressive economic campaign against Iran, marking a stark divergence in approach to two long-standing sanctions programs. Treasury's actions include removing Syria's State Sponsor of Terrorism designation and delisting HTS, while initiating "Operation Economic Outcast" targeting five sectors of Iran's economy with expanded secondary sanctions. These coordinated moves demonstrate the administration's willingness to purs
GlobalInternational Law
Arnold & Porter
Arnold & Porter
Article

FTC Issues Rigorous Requirements On Using AI-Assisted Review Or Technology-Assisted Review To Respond To Investigational Subpoenas

The Federal Trade Commission has introduced stringent new requirements for parties using technology-assisted review or artificial intelligence in document production during investigations, mandating extensive upfront disclosures, prescriptive performance metrics, and validation processes. These requirements represent a significant departure from previous FTC practice and may discourage parties from using AI or TAR due to increased complexity and agency oversight. Parties now face critical decisions about wh
United StatesLitigation, Mediation & Arbitration
Arnold & Porter
Arnold & Porter