The U.S. Environmental Protection Agency (EPA) has announced a significant proposal to adjust reporting rules for per- and polyfluoroalkyl substances (PFAS) under the Toxic Substances Control Act (TSCA) in November 10, 2025. If finalized, manufacturers will no longer be required to submit extensive data to the EPA for four key scenarios: low concentrations, imported articles, small-scale research and development (R&D), and specific byproducts or impurities.
In October 2023, the Biden administration introduced a mandatory PFAS reporting rule under TSCA Section 8(a)(7), requiring companies that manufactured or imported PFAS between 2011 and 2022 to submit data on chemical exposure and environmental impact. However, this rule faced widespread criticism due to implementation challenges, including:
• Estimated compliance costs nearing $10 billion;
• Lack of clarity on how the collected data would be utilized;
• Practical difficulties such as IT system failures and administrative delays, which placed undue burden on small businesses and importers.
The newly proposed adjustments aim to introduce certain exemptions and modifications to reduce unnecessary reporting burdens while maintaining essential oversight of PFAS.
1. Low-Concentration Exemption: Mixtures or articles containing PFAS at concentrations below 0.1% are exempt from reporting.
2. Imported Articles Exemption: Imported items containing PFAS are exempt from reporting.
3. Byproducts, Impurities, and Non-Isolated Intermediates Exemption: PFAS manufactured as byproducts, impurities, or non-isolated intermediates are exempt.
4. R&D Exemption: Small quantities of PFAS used for research and development purposes are exempt.
Adjustments to Data Submission Timeline
The EPA proposes extending the data submission window to three months, starting 60 days after the final rule takes effect.
• Clarifies reporting requirements for environmental and health impact information.
• Updates terminology for consumer and commercial product categories.
The EPA is accepting public comments on the proposed rule until December 29, 2025. If implemented, the exemptions are expected to save the industry between $786 million and $843 million in compliance costs, significantly reducing the burden on small businesses.
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