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ARTICLE · 25 NOVEMBER 2025

PFAS Compliance Update: How EPA's Proposed TSCA Rule Could Affect Your Business

Phelps Dunbar LLP
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If your business imports articles containing PFAS, you may be entirely exempt from future reporting requirements. The U.S. Environmental Protection Agency (EPA)'s newly proposed changes...

United StatesEnvironment
Sophie D. Gray
Sophie D. Gray
Semaj Fielding
Semaj Fielding

If your business imports articles containing PFAS, you may be entirely exempt from future reporting requirements. The U.S. Environmental Protection Agency (EPA)'s newly proposed changes to the Toxic Substances Control Act (TSCA) could significantly reshape reporting obligations for manufacturers and importers of PFAS and PFAS-containing articles.

What's the TSCA?

Through TSCA, the EPA regulates commercial uses of chemical substances that are not regulated by other federal statutes. As originally drafted, the 2023 "Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS)" rule issued under TSCA Section 8(a)(7) required all manufacturers and importers of PFAS and importers of PFAS-containing mixtures or articles to report information about their PFAS-related activities between 2011 and 2022.

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