US EPA Extends TSCA PFAS Reporting Rule

SG 063/26

US Environmental Protection Agency (EPA) issues third extension for its per- and polyfluoroalkyl substances (PFAS) Reporting Rule

In 2023, the EPA issued the ‘Toxic Substances Control Act Reporting and Recordkeeping Requirements for PFAS’ (TSCA Section 8(a)(7) PFAS Reporting Rule). This rule added Part 705 to the Title 40 Code of Federal Regulations (40 CFR Part 705). It requires manufacturers (which also include importers by statute) that manufacture or have manufactured PFAS, mixtures containing PFAS or PFAS-containing articles between January 1, 2011, and December 31, 2022, to report designated PFAS compounds to the EPA.

Since the rule’s publication, the reporting period has been extended twice, most recently to April 13, 2026, under the interim final rule issued in May 2025, after an earlier extension in September 2024 under the direct final rule (SafeGuardS 67/25 and references therein).

On April 13, 2026, the EPA issued a final rule in the Federal Register (91 FR 18786), revising the start of the submission period for the TSCA PFAS Reporting Rule.

What does this final rule require?

Key provisions in the final rule include:

• Amending the submission period to commence on January 31, 2027, or 60 days after the date identified by 40 CFR 705.20(c) (to be added by a subsequent final rule to address the remaining topics in the November 2025 proposal, see Table 1).
• Clarifying that the extension provides the agency with additional time to consider and respond to comments on both the interim final rule (issued in May 2025) and the proposed rule (published in November 2025), before publishing any appropriate final rule.

Highlights of the final rule are summarized in Table 1.

Table 1

Who is impacted?

The final rule applies to manufacturers (which, by statute, also covers importers) that manufactured PFAS, or mixtures and articles containing PFAS, between January 1, 2011, and December 31, 2022.

When does it apply?

The final rule became effective on April 13, 2026.

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