US EPA final rule delays start of TSCA §8(a)(7) PFAS reporting submission period; adds backstop start date

EPA finalized a rule modifying the start of the TSCA §8(a)(7) PFAS reporting submission period (40 CFR Part 705). Instead of beginning on April 13, 2026, the submission period will begin on the earlier of (i) January 31, 2027, or (ii) 60 days after the effective date of a forthcoming final rule revising the substantive requirements. This changes compliance planning for entities that manufactured or imported PFAS (including PFAS in articles) in any year 2011–2022 by delaying when submissions can/must begin, while also creating a trigger tied to the effective date of a separate forthcoming final action.