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ARTICLE · 17 NOVEMBER 2025

EPA Proposes To Scale Back TSCA PFAS Reporting Rule, Including New Exclusion For Imported Articles

Beveridge & Diamond, P.C.
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The U.S. Environmental Protection Agency (EPA) is proposing revisions to the reporting rule for per- and polyfluoroalkyl substances (PFAS) under the Toxic Substances Control Act (TSCA).

United StatesEnvironment
Ryan J. Carra
Ryan J. Carra
Mark N. Duvall
Mark N. Duvall
Robert T. Denney
Robert T. Denney
Elizabeth Nugent Morrow
Elizabeth Nugent Morrow

The U.S. Environmental Protection Agency (EPA) is proposing revisions to the reporting rule for per- and polyfluoroalkyl substances (PFAS) under the Toxic Substances Control Act (TSCA). First promulgated in 2023, the PFAS Reporting Rule in its current form is wide-sweeping, applying to all companies that domestically manufactured PFAS or imported PFAS-containing items during 2011-2022. The current rule includes essentially no exemptions, and now EPA is proposing to change that.

EPA's proposal would incorporate exemptions for imported articles; de minimis concentrations of PFAS at 0.1% or lower; byproducts, impurities, and non-isolated intermediates; and for research and development (R&D). EPA is also proposing certain clarifications, technical corrections, and to key the submission period to the effective date of the finalized revisions. The most prominent of these proposed revisions is the imported articles exemption, which would remove from the rule's scope the

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