EPA proposes amendments to TSCA PFAS one-time reporting rule to add exemptions and adjust reporting mechanics

EPA issued a proposed rule (prepublication document signed Nov 10, 2025) to revise the TSCA §8(a)(7) PFAS data reporting and recordkeeping requirements (one-time reporting covering PFAS manufactured/imported during 2011–2022). The proposal would make reporting more practical by introducing/clarifying multiple exemptions and scope limitations (including imported articles and a de minimis threshold of ≤0.1% in mixtures/products, plus exemptions for certain byproducts, impurities, R&D, and non-isolated intermediates), along with technical corrections and adjustments to the submission period. EPA indicated a public comment period of 45 days upon Federal Register publication. Compliance teams should evaluate whether their PFAS-related activities could become exempt (e.g., article importers) and track the final rule and any changes to submission timing and data elements.