EPA proposes changes to make TSCA PFAS reporting requirements more practical (scope/exemptions proposal)

EPA proposed revisions to the TSCA Section 8(a)(7) PFAS reporting and recordkeeping rule intended to reduce reporting burden by proposing changes to scope and exemptions (as described in EPA communications), including potential exclusions for certain PFAS in products/mixtures at low concentrations, certain imported articles, certain byproducts/impurities, R&D chemicals, and non-isolated intermediates. If finalized, these changes could materially alter who must report and what activities are reportable under 40 CFR Part 705; compliance teams should monitor the proposal and evaluate how potential exemptions would change reporting applicability and data-collection needs.