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ARTICLE · 20 NOVEMBER 2025

EPA Proposes Sweeping Changes To TSCA PFAS Reporting

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EPA's 2025 proposal, announced yesterday, would add several exemptions—most notably for imported products, de minimis concentrations, and certain byproducts and impurities—while making technical clarifications and adjusting the compliance deadline.

United StatesEnvironment
Lorene L. Boudreau
Lorene L. Boudreau
Erin M. Carter
Erin M. Carter
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Summary

The Environmental Protection Agency (EPA) announced targeted amendments to its 2023 PFAS Data Reporting and Recordkeeping Rule, which requires collection and reporting on per- and polyfluoroalkyl substances (PFAS) manufacturing and importing that occurred from 2011 through 2022, under Toxic Substances Control Act (TSCA) section 8(a)(7).

EPA's 2025 proposal, announced yesterday, would add several exemptions—most notably for imported products, de minimis concentrations, and certain byproducts and impurities—while making technical clarifications and adjusting the compliance deadline. EPA frames the changes as reducing burdens on entities least likely to have relevant information, particularly small businesses, while preserving the data needed to inform future TSCA actions on PFAS.

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