Everything You Need to Know About the EPA’s PFAS Reporting Requirements

Article Highlights:

• The EPA’s PFAS reporting requirements fall under Section 8(a)(7) of TSCA, titled Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances. The rule mandates that in-scope companies report detailed information on the PFAS substances they’ve used, manufactured, and/or imported dating all the way back to January 1, 2011.
• In general, the reporting obligation applies to U.S. manufacturers who produce PFAS substances and/or incorporate them into their product formulations, as well as companies that import articles containing PFAS.
• In April 2026, the EPA finalized a rule that postponed the start of the PFAS reporting period again. Instead of beginning on April 13, the submission window for covered businesses is now expected to begin on one of two potential dates. 

The PFAS reporting requirements introduced by the U.S. Environmental Protection Agency (EPA) are rapidly becoming one of the more significant compliance challenges for American manufacturers, importers, and downstream users. While the agency’s new PFAS reporting rule, which was finalized in the fall of 2023, may be a onetime compliance obligation, that doesn’t make it any less of a formidable regulatory challenge for businesses. As EPA regulators prepare to scrutinize PFAS use across the rule’s considerable scope, companies must act quickly to understand their obligations, assess their exposure, and implement processes that help solidify their adherence.

PFAS—often called “forever chemicals”—have been widely used in consumer products and industrial applications for decades. But growing concerns about their environmental persistence and potential human health impacts have prompted regulatory bodies all over the world to start assuming a stricter stance on these substances. The EPA’s new PFAS reporting requirement is one manifestation of that new approach. With the information it gathers following the reporting period, the agency hopes to produce a clearer picture of PFAS usage across supply chains.

What Are PFAS and Why Are They Regulated?

PFAS—which is short for per- and polyfluoroalkyl substances—are a large class of synthetic chemicals used in everything from nonstick cookware and waterproof fabrics to firefighting foams and electronics manufacturing. But while the durability these chemicals demonstrate has made them extremely popular in manufacturing, that durability is precisely what makes them problematic, too. PFAS don’t break down easily in the environment or the human body, and their long half-lives mean they can persist for years and even decades in water, soil, and living organisms. 

Regulatory bodies like the EPA are increasingly focused on PFAS due to several health and environmental hazards.

• Potential links to health issues such as cancer, immune system dysfunction, and hormone disruption.
• Widespread environmental contamination in water, soil, and air.
• Bioaccumulation in humans and wildlife.

These concerns have led to expanding legislation worldwide—including the EPA’s PFAS reporting rule. 

What Are the EPA’s PFAS Reporting Requirements?

The EPA’s PFAS reporting requirements fall under Section 8(a)(7) of TSCA, titled Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances. The rule mandates that in-scope companies report detailed information on the PFAS substances they’ve used, manufactured, and/or imported dating all the way back to January 1, 2011.

One critical factor to bear in mind is that this is not a permanent regulation. Rather, it’s a onetime retrospective reporting obligation. Companies must provide historical usage data going back more than a decade, even if PFAS are no longer part of their current operations. But once they’ve reported their PFAS use to the EPA, they have no further obligations under TSCA Section 8(a)(7).

Key elements of the EPA’s PFAS reporting requirements include:

• Scope: Applies to any PFAS manufactured or imported in any year since 2011.
• Threshold: There’s no minimum, and even small quantities must be reported.
• Chemical Definition: Covers hundreds of PFAS substances.

Companies must provide historical usage data going back more than a decade, even if PFAS are no longer part of their current operations.

Who Has to Comply with PFAS Reporting Requirements?

The first step organizations should take to address this regulatory challenge is determining whether or not they’re in the scope of the EPA’s PFAS reporting rule. In general, the reporting obligation applies to U.S. manufacturers who produce PFAS substances and/or incorporate them into their product formulations, as well as companies that import articles containing PFAS.

The latter group is noteworthy, because it expands the regulation’s scope significantly. Businesses that don’t consider themselves chemical manufacturers—such as consumer electronics companies, automakers, or apparel brands—may still be subject to the PFAS reporting requirements if their products contain any forever chemicals. 

While there are exemptions, they are narrow and limited. Businesses should not hope or assume that their organization will qualify for these regulatory exceptions. 

What Information Must Be Reported Under TSCA Section 8(a)(7)?

The EPA is requiring covered businesses to submit detailed data on their use of PFAS over the past decade-and-a-half. These requirements include:

• Identity and structure of the PFAS chemicals used.
• Categories of use, including industrial, commercial, and consumer.
• Production volumes for each year dating back to 2011.
• Byproducts and environmental discharge.
• Worker exposure data.
• Waste management methods.

For many organizations, this information won’t be readily accessible in existing databases or compliance systems. Instead, companies will need to obtain PFAS usage information for the first time, including by reaching out to suppliers and other upstream manufacturers, collecting data internally and externally, and analyzing product and manufacturing documentation going back 15 years. 

Key Deadlines for PFAS Reporting Requirements

The timeline for PFAS reporting requirements has evolved significantly over the past two years. In the past 12 months alone, there have been multiple revisions and delays announced by the EPA. As of 2026, companies must pay close attention to the latest updates, as guidance issued as recently as late 2025 and even early 2026 may now be superseded by new guidelines. 

The Original 2023 TSCA Section 8(a)(7) Timeline 

When the rule was first finalized in October 2023, the EPA intended for reporting to begin on November 12, 2024, with the submission window lasting for six months for most in-scope businesses. Smaller manufacturers were expected to have a 12-month window that would extend into late 2025. That timeline was eventually pushed, with the EPA moving the reporting window to April 13, 2026. 

However, as of April 2026 this timeline is no longer valid, either. 

The EPA Postpones the Reporting Window Again

In April 2026, the EPA finalized a rule that postponed the start of the PFAS reporting period again. Instead of beginning on April 13, the submission window for covered businesses is now expected to begin on whichever of the following dates comes first: 

• January 31, 2027 
• 60 days after the effective date of the EPA’s forthcoming final rule addressing PFAS reporting requirements.

As the fluid timeline implies, the EPA is still finalizing updates to the rule—including potential exemptions and scope adjustments. The agency wants to make sure that all these modifications are finalized before organizations start submitting data.

Has the EPA PFAS Reporting Window Length Changed?

The duration of the reporting period is another aspect of the EPA rule that may be changed over the course of 2026. The existing rule stipulates that most covered companies have a six-month reporting window, with an additional six months for smaller manufacturers who are reporting only as article importers. 

With the proposed revisions, however, that window may be reduced to three months. But until the EPA issues its final revised rule, companies should be prepared for either scenario—including a shorter three-month timeframe that will require covered organizations to participate in a faster submission process.

Broader Implications of PFAS Reporting Requirements

Beyond the immediate compliance obligations, the EPA’s PFAS reporting requirements signal a broader shift in regulatory expectations. Regulatory agencies all over the world are taking PFAS more seriously, and businesses should not be blindsided if and when local, state, and national agencies begin implementing more stringent restrictions on PFAS use. 

Companies should be prepared for a myriad of new PFAS-related regulations:

• Increased restrictions or bans on certain substances.
• Greater demand for transparency from customers and stakeholders.
• Heightened enforcement and potential penalties for noncompliance.
• Expansion of similar regulations globally.

While the EPA’s reporting requirements are a one-time obligation, they are far from the only time businesses will need to comply with emerging PFAS directives in the near future. Rather, TSCA Section 8(a)(7) is part of a larger trend toward stricter chemical regulations and more robust supply chain accountability.

Regulatory agencies all over the world are taking PFAS more seriously, and businesses should not be blindsided if and when local, state, and national agencies begin implementing more stringent restrictions on PFAS use. 

Prepare for Expanding Chemical Regulations With Z2

While the PFAS reporting requirements present clear challenges, they also offer an opportunity for organizations to strengthen their internal compliance programs, improve their supply chain visibility, and build proactive resilience against future regulatory obstacles.

Compliance platform Z2 can help businesses successfully take advantage of all those opportunities. Z2 works with companies to achieve compliance with over 180 global regulations that span chemical, product, trade, and ESG, including REACH, RoHS, EUDR, SCIP, California Proposition 65, and PFAS. By partnering with Z2, businesses are able to:

• Understand their full regulatory data requirements.
• Rely on a team of experts to carry out supply chain due diligence.
• Participate in a full compliance risk analysis.
• Receive reports and declarations for all their compliance obligations.

To learn more about Z2Data’s compliance services, schedule a free trial with one of our product experts.