EPA final rule modifies start trigger for TSCA §8(a)(7) PFAS reporting submission period (60-day trigger; Jan 31, 2027 backstop)

EPA finalized a change to the start of the submission period for the TSCA §8(a)(7) PFAS Reporting and Recordkeeping Rule (40 CFR Part 705). Instead of a fixed start date, the submission period will begin 60 days after the effective date of a forthcoming final rule that revises the substantive requirements, or on January 31, 2027, whichever is earlier. This directly affects compliance planning, internal calendars, and resourcing for entities that manufactured (including imported) PFAS during the covered period.