EPA Extends PFAS Reporting Start Date under TSCA Section 8(a)(7)

At a Glance

• The reporting period for PFAS data will now begin on January 31, 2027, or 60 days following the effective date of a forthcoming final rule on substantive PFAS reporting requirements, whichever is earlier.
• The revised start date provides businesses with additional lead time to prepare for compliance, reducing the risk of unnecessary or misaligned reporting efforts if substantive requirements change before the reporting period begins. Entities should continue to monitor EPA developments.

On April 8, 2026, the US Environmental Protection Agency (EPA) finalized a rule that postpones the start date for mandatory reporting and recordkeeping of per- and polyfluoroalkyl substances (PFAS) under Section 8(a)(7) of the Toxic Substances Control Act (TSCA). Prior to this rule, the reporting period was slated to begin on April 13, 2026, despite ongoing substantive rulemaking.

TSCA 8(a)(7) PFAS Reporting

On October 11, 2023, EPA finalized reporting and recordkeeping requirements for PFAS under TSCA Section 8(a)(7). The rule requires any person that manufactured — including imported — PFAS or PFAS-containing articles in any year since January 1, 2011, to report information regarding the PFAS.

Prior to this announcement, EPA has twice delayed the reporting deadline, first in September 2024 and again in May 2025. Then in November 2025, EPA proposed substantive changes to the scope of PFAS reporting obligations. These changes would incorporate additional exemptions and modifications to limit the scope of reporting. Public comment on this rule ended on December 29, 2025, and EPA is currently reviewing the comments received.

Updated Reporting Timeline

The reporting period for PFAS data will now begin on January 31, 2027, or 60 days following the effective date of a forthcoming final rule on substantive PFAS reporting requirements, whichever is earlier. The "backstop" date ensures that the reporting period will not be delayed beyond January 31, 2027, even if the substantive rulemaking is not finalized by then; although EPA states that it anticipates a final rule "well before" the January 31, 2027, deadline.

The rule addresses only the timing for when companies must begin submitting PFAS-related data to the EPA. It does not alter the substantive reporting requirements themselves. The rule also retains the reporting windows, which will be six-months' long for most entities; while small manufacturers who report only as article importers will have a 12-month reporting window beginning on the same start date.

EPA made this change to allow for additional time to consider and respond to comments on both the interim final rule (published on May 13, 2025) and the proposed rule (published on November 13, 2025). In the pre-publication notice, EPA stated that it needs additional time to address comments, write and publish a final rule, release updated guidance, and update its reporting tool. The need to update the reporting tool was cited as the reason for the prior deadline extensions.

Next Steps

The revised start date provides businesses with additional lead time to prepare for compliance, reducing the risk of unnecessary or misaligned reporting efforts if substantive requirements change before the reporting period begins. Entities should continue to monitor EPA developments. The agency anticipates a subsequent final rule addressing other possible changes to the reporting scope, exemptions, and final deadlines will be published later this year. For more information, see EPA's Pre-publication Notice.