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ARTICLE · 20 APRIL 2026

TSCA PFAS Reporting Postponed Again

Bryan Cave Leighton Paisner
Bryan Cave Leighton Paisner
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Bryan Cave Leighton Paisner

Bryan Cave Leighton Paisner

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The United States Environmental Protection Agency (“EPA”) has announced it will again delay the start of the data submission period for the Toxic Substances Control Act (“TSCA”)...

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The United States Environmental Protection Agency (“EPA”) has announced it will again delay the start of the data submission period for the Toxic Substances Control Act (“TSCA”) Section 8(a)(7) reporting requirement for per- and polyfluoroalkyl substances (“PFAS”), previously slated to begin April 13, 2026. According to a pre-published version of EPA’s rule modifying the submission period timeline, this action officially shifts the start of the reporting period to either January 31, 2027, or “to 60 days following the effective date of the agency’s forthcoming revision to the PFAS 8(a)(7) rule,” whichever is earlier. 

In a published announcement regarding its adjustment to the submission period start date, EPA cited the agency’s need to “review the thousands of public comments on the November 2025 proposed updates [to the PFAS 8(a)(7) rule] so that the agency can refine the rule to better deliver timely, actionable reporting guidance without unnecessary loopholes that could delay

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