On September 5, 2024, the United States Environmental Protection
Agency (U.S. EPA) issued a direct final rule that delays the submission
deadline for its Toxic Substances Control Act (TSCA) reporting
requirements for per- and polyfluoroalkyl substances (PFAS).
This rule provides a bit of a reprieve for many manufacturers
(including importers) of products and articles that may contain
PFAS, particularly given the breadth of these reporting obligations
and the 12 years of data that will need to be reported. Under the
original TSCA rule, the portal for electronic reporting was set to
open November 12, 2024, and close May 8, 2025. This new rule pushes
these dates back, with the portal now set to open July 11, 2025,
and final report submissions are due by January 11, 2026.
Manufacturers that qualify under TSCA as small manufacturers
reporting only article imports will have until July 11, 2026, to
submit final reports.
