US EPA again revised the reporting deadlines for manufacturers and importers of PFAS under the Toxic Substances Control Act (TSCA) Section 8(a)(7) rule. Like the prior extension, US EPA states that it needs additional time to create the reporting application and ensure its performance. Notably, US EPA is also considering reopening the rule and with the additional time US EPA will be able to “consider public comments and propose and finalize any modifications to the rule…” This action does not discuss what potential changes may come.
Originally, the reporting period was set to begin on November 12, 2024. That was delayed on September 5, 2024, with a new reporting period to begin on July 11, 2025. Under this latest interim final rule, the reporting period does not start until April 13, 2026, with a deadline of October 13, 2026, for most companies. For small businesses that are reporting only article imports, the additional six months provides a reporting deadline of April 13, 2027. The latest extension has not yet been published in the Federal Register but is expected early this week. An unpublished form is available here.
If you have any questions about your reporting obligations under the rule or would like to participate in future public comments on potential rule changes, please contact Jake Bartlett or your Vorys attorney.