EPA issued an interim final rule extending the TSCA Section 8(a)(7) PFAS reporting submission period. The rule provides additional time due to EPA's inability to conduct planned beta testing of the CDX reporting application. Under this interim rule, most manufacturers must submit reports by October 13, 2026, while small businesses reporting solely on PFAS contained in imported articles have until April 13, 2027.
Under TSCA Section 8(a)(7), the US Environmental Protection Agency (EPA) requires manufacturers (including importers) of per- and polyfluoroalkyl substances (PFAS) to submit one-time retrospective reports covering PFAS manufactured or imported since January 1, 2011. The rule aims to enhance federal oversight by collecting detailed information on PFAS production volumes, uses, exposure pathways, and potential environmental and human health impacts. Reporting opens April 13, 2026; submissions are due by October 13, 2026, with small manufacturers allowed until April 13, 2027
An ECHA Weekly item reports that the European Commission adopted amendments affecting the specific exemption for installed firefighting foam systems containing PFOA, its salts, and related substances, including extending the exemption expiry date and setting new concentration limits for PFOA-related compounds in foam. Compliance teams managing firefighting foams and installed suppression systems should review whether foam formulations and installed systems remain eligible under revised exemption timing/limits and update procurement/replacement plans accordingly.
ECHA’s Weekly update reports that the European Commission adopted amendments (reported as adopted 5 May 2025) to Annex I of the EU POPs Regulation affecting PFOA, its salts and PFOA-related substances in firefighting foams. The update indicates (1) an extension of the expiry date of the specific exemption for use of firefighting foams already installed in systems containing PFOA-related substances, and (2) new concentration limits for PFOA-related compounds in firefighting foam. Compliance teams managing AFFF/installed suppression systems and PFAS waste streams should review the updated exemption conditions and concentration limits to confirm continued eligibility and any phase-out/transition planning.
EPA (via EPCRA SERC/TERC Update) announced the automatic addition of nine PFAS to the Toxics Release Inventory (TRI) list effective January 3, 2025. This expands the PFAS subject to TRI reporting and impacts covered facilities’ chemical tracking and TRI Form R/Form A reporting for Reporting Year 2025 (with forms due July 1, 2026, as stated in the update). Compliance teams at TRI-covered facilities should update chemical inventories, supplier declarations, and reporting systems to ensure these PFAS are captured for applicable release and waste management reporting.
EPA’s EPCRA/TRI communications describe (1) an automatic addition of nine PFAS to the Toxics Release Inventory (TRI) as of January 3, 2025 under the FY2020 NDAA mechanism, expanding the set of PFAS subject to TRI reporting, and (2) an associated EPA proposal (referenced in the update) intended to clarify when supplier notifications must begin for PFAS automatically added to TRI. Compliance teams at TRI-covered facilities and upstream suppliers should reassess TRI applicability for newly added PFAS, update chemical inventories, and plan for applicable reporting/supplier-notification timing (including Reporting Year 2025 forms due July 1, 2026 as referenced).
EPA reported that nine PFAS were automatically added to the EPCRA §313 Toxics Release Inventory (TRI) effective January 3, 2025, increasing the total number of PFAS subject to TRI reporting. EPA also referenced a proposed rule to clarify supplier notification timing related to these automatic PFAS additions. Compliance teams subject to TRI should ensure TRI applicability screening and supplier notification workflows reflect the expanded PFAS list for the relevant reporting year and monitor the proposed supplier-notification clarification.
EPA published a final rule in the Federal Register implementing the statutory addition of certain PFAS to the Toxics Release Inventory (TRI) starting with Reporting Year 2025. Compliance teams subject to EPCRA Section 313 TRI reporting should validate whether any newly added PFAS are manufactured, processed, or otherwise used above TRI thresholds and ensure TRI systems, supplier declarations, and chemical inventories are updated for the new reporting year scope.
Minnesota’s first phase of statutory PFAS use prohibitions takes effect starting January 1, 2025 (as summarized by the Minnesota Pollution Control Agency). Compliance teams supplying into Minnesota should confirm whether any products/uses they place on the market fall into the prohibited categories effective on this date and update product stewardship, material declarations, and procurement controls accordingly.
Minnesota’s Pollution Control Agency compliance page confirms that, starting January 1, 2025, the first product prohibitions under Amara’s Law (Minn. Stat. § 116.943) apply: products in specified categories may not be sold/distributed in Minnesota if they contain intentionally added PFAS. For compliance teams, this is a binding sales/distribution restriction that requires product-content diligence (PFAS intentional addition) and market access controls for Minnesota.
EPA released a pre-publication Federal Register notice for the proposed 2026 Multi-Sector General Permit (MSGP) for industrial stormwater that includes a new provision for PFAS “indicator monitoring” (described as quarterly, report-only analytical monitoring for PFAS for many sectors). This creates a potential new PFAS monitoring expectation for facilities operating under the MSGP in EPA-permitting areas. Compliance teams should identify affected sites/sectors, assess sampling/analytical feasibility and cost, and prepare to submit comments once the proposal is formally published (comment deadline stated as 60 days after Federal Register publication).
EPA’s Proposed 2026 NPDES Multi-Sector General Permit (MSGP) fact sheet includes a new provision for certain industrial sectors to conduct quarterly, report-only indicator analytical monitoring for PFAS. The fact sheet references monitoring for a suite of PFAS compounds aligned with EPA Method 1633, with analysis using EPA Method 1633. Facilities that rely on MSGP coverage should evaluate whether their sector would be subject to PFAS monitoring and prepare for potential sampling/lab capacity and internal reporting workflows if finalized.
EPA published a fact sheet for the proposed 2026 NPDES Multi-Sector General Permit (MSGP) describing 'report-only' indicator analytical monitoring for PFAS on a quarterly basis (as described in the fact sheet). This signals potential new monitoring and reporting expectations for MSGP-covered industrial sectors if finalized; environmental compliance teams should review whether their facilities would be covered and plan for sampling, lab capacity, and data management impacts pending final permit issuance.
EPA issued a direct final rule under TSCA Section 8(a)(7) changing the data submission period for PFAS reporting (40 CFR Part 705), delaying the start date from November 12, 2024 to July 11, 2025 with corresponding changes to end dates. The agency cited budgetary constraints affecting timely development and testing of the Central Data Exchange (CDX) reporting application as the reason for the delay. This action provided additional time for EPA to complete the reporting application and for manufacturers to prepare for compliance.