EPA final rule delays start of TSCA PFAS one-time reporting submission period; ties start to future final revisions with Jan 31, 2027 backstop

EPA finalized a change to the TSCA §8(a)(7) PFAS reporting timeline: the start of the submission period is no longer a fixed April 13, 2026 date. Instead, the reporting window will begin 60 days after the effective date of a forthcoming final rule revising the PFAS reporting regulation, with a backstop start date of January 31, 2027 (whichever is earlier, as described in the signed pre-publication final rule). This affects entities that manufactured (including imported) PFAS during the 2011–2022 lookback period (including certain article importers), requiring compliance teams to re-baseline project plans for data collection, supplier outreach, and internal system readiness against the new trigger-based start date.