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

EPA issued a proposed rule to revise the TSCA Section 8(a)(7) one-time PFAS reporting and recordkeeping requirements (covering PFAS manufactured/imported during 2011–2022) to make the program more practical/implementable. The proposal includes new/expanded exemptions and changes to reporting mechanics (e.g., potential exclusions for certain PFAS in products/mixtures at low concentration, imported articles, byproducts, impurities, R&D, and non-isolated intermediates, as described in the research summary) and would alter what information companies must submit and who must report. Compliance teams should evaluate whether their products/import streams could fall within proposed exemptions, prepare to submit comments within the comment period, and plan for potential scope changes that could reduce or reshape reporting obligations if finalized.