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ARTICLE · 03 DECEMBER 2025

EPA Proposes Updates To PFAS Reporting Requirements Under TSCA

Shook, Hardy & Bacon LLP
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On November 10, 2025, the U.S. Environmental Protection Agency (EPA) announced proposed changes to its reporting requirements for per- and polyfluoroalkyl substances (PFAS) under the Toxic Substances Control Act (TSCA).

United StatesEnvironment
Christopher M. Sorenson
Christopher M. Sorenson

On November 10, 2025, the U.S. Environmental Protection Agency (EPA) announced proposed changes to its reporting requirements for per- and polyfluoroalkyl substances (PFAS) under the Toxic Substances Control Act (TSCA). These changes aim to make compliance more practical for businesses while ensuring that regulators receive data necessary to regulate these compounds under the TSCA.

In 2023, EPA finalized a one-time PFAS reporting rule under TSCA Section 8(a)(7), requiring manufacturers and importers to report data on PFAS produced or imported between 2011 and 2022. While intended to improve transparency, the rule imposed significant compliance costs—estimated at nearly $1 billion—without clear implementation standards. The new proposal seeks to reduce unnecessary burdens while maintaining robust data collection by implementing the following changes:

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