EPA proposes changes to TSCA PFAS §8(a)(7) reporting requirements to add exemptions and adjust reporting mechanics

EPA issued a proposal to revise the TSCA §8(a)(7) PFAS reporting and recordkeeping rule to make the requirements more practical/implementable. The proposal describes potential exemptions (e.g., certain impurities, byproducts, R&D, non-isolated intermediates, imported articles, and mixtures/products at or below a concentration threshold) and other changes such as technical corrections and adjustments to reporting mechanics/submission period. Compliance teams should review applicability and prepare to comment and/or reassess reporting scoping assumptions for 2011–2022 PFAS manufacturing/import activity.