The interim final rule issued by the EPA states that the “change is necessary because EPA requires more time to prepare the reporting application to collect this data.”

On May 12, 2025, the U.S. Environmental Protection Agency (EPA) announced that it is amending the data submission period for the Toxic Substances Control Act’s (TSCA) per- and polyfluoroalkyl substances (PFAS) reporting rule to begin on April 13, 2026, and end on October 13, 2026. Small manufacturers reporting exclusively as article importers will have until April 13, 2027, to complete their reporting. 

The interim final rule issued by the EPA states that the “change is necessary because EPA requires more time to prepare the reporting application to collect this data.” The interim rule also states that while the EPA is not making any other changes to the reporting rule at this time, it “is separately considering reopening certain aspects of the rule to public comment,” and the “delayed reporting date ensures that EPA has adequate time to consider the public comments and propose and finalize any modifications to the rule before the submission period begins.”

The interim final rule delaying the data submission period was published in the Federal Register May 13, 2025, and is effective immediately. However, the EPA is still accepting public comments on the interim rule for a period of 30 days.

As previously reported, the EPA released its final TSCA Section 8(a) PFAS reporting rule in September 2023. The rule imposes reporting and recordkeeping requirements on manufacturers (including importers) of PFAS in any year between 2011 and 2022. 

This is the second time the agency has pushed back the submission period.

Duane Morris will continue monitoring any proposed changes to the reporting rule.

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