EPA Extends TSCA 8(a)(7) PFAS Reporting to October 2026

At a Glance

• This is the second extension of the Section 8(a)(7) deadline — the original submission period was set to run from November 12, 2024, to May 8, 2025. EPA’s stated reason for both extensions was that the agency needed additional time to prepare and test the reporting application, CDX.
• While the submission period has been delayed, the reporting requirements have not changed. Companies within the scope of the PFAS reporting rule should continue to collect the required data in preparation for next year’s reporting deadline.

On May 13, 2025, the Environmental Protection Agency (EPA or the Agency) issued an interim final rule extending the data submission period for the Toxic Substances Control Act (TSCA) Section 8(a)(7) perfluoroalkyl and polyfluoroalkyl substances (PFAS) reporting rule. The PFAS reporting rule requires any person that has manufactured or imported PFAS or PFAS-containing articles in any year since January 1, 2011, to electronically report certain information regarding PFAS uses, production volumes, disposal, exposure and hazards. The interim rule delays the deadline for reporting this information from January 11, 2026, to October 13, 2026. Instead of EPA’s Central Data Exchange (CDX) opening in July 2025, it will open in April 2026.

This interim rule comes on the heels of EPA Administrator Lee Zeldin’s April 28, 2025, announcement affirming EPA’s intent to implement TSCA Section 8(a)(7) reporting requirements for PFAS. The previous announcement indicated EPA may expand exemptions in the PFAS reporting rule to minimize burdens on small businesses and article importers. However, while the interim rule states that EPA may reopen certain aspects of the rule to public comment in the future, this current action addresses only the deadline for submission.

Key Dates

Under the interim final rule, reporting dates for manufacturers and importers are as follows:

• Submission period begins: April 13, 2026
• Submission period ends: October 13, 2026
• Extended submission period for small manufacturers reporting exclusively as article importers ends: April 13, 2027

This is the second extension of the Section 8(a)(7) deadline — the original submission period was set to run from November 12, 2024, to May 8, 2025. EPA’s stated reason for both extensions was that the agency needed additional time to prepare and test the reporting application, CDX, to ensure it will function correctly and securely. Interestingly, the Agency did not focus on easing the burden on the regulated community as a reason for either extension.

Reporting Requirements

All companies impacted by the rule will be required to submit certain data to EPA through CDX. Reportable information includes:

• Chemical Information: Common/trade name, chemical identity, and molecular structure of each PFAS substance or mixture
• Usage Categories: Current or proposed usage categories for each PFAS substance or mixture
• Production Amounts: Total and category-specific amounts of PFAS manufactured or processed, with estimates for proposed amounts
• Byproducts: Descriptions of byproducts from manufacture, processing, use or disposal of PFAS
• Health and Environmental Effects: Existing information on environmental and health impacts of PFAS
• Exposure Estimates: Number of individuals exposed or estimated to be exposed to PFAS substances or mixtures at work, and duration of exposure
• Disposal Methods: Current disposal methods, and any changes in methods, for each PFAS substance or mixture

While the submission period has been delayed, the reporting requirements outlined above have not changed. Companies within the scope of the PFAS reporting rule should continue to collect the required data in preparation for next year’s reporting deadline.

Comment Period

Though the interim final rule became effective as of publication on May 13, 2025, EPA is still soliciting comments on the rule for a 30-day period following publication. Companies who wish to comment on the amendment of the submission period may submit comments at Regulations.gov. The interim final rule also states that EPA intends to issue a separate notice of proposed rulemaking in the near future that will, among other things, allow for further comment on the appropriate reporting period. EPA states it intends to address comments in response to this final rule and the notice of proposed rulemaking concurrently, and to publish a final rule.