The US Environmental Protection Agency has again postponed reporting under the Toxic Substances Control Act PFAS rule, established under TSCA Section 8(a)(7) and codified at 40 CFR Part 705. The rule requires companies that manufactured or imported PFAS, including PFAS-containing articles, during 2011–2022 to report chemical identity, uses, production volumes, byproducts, exposure, disposal and available health or environmental information.

Under EPA’s April 2026 final action, the submission period will begin 60 days after the effective date of a forthcoming substantive revision, or on 31 January 2027, whichever occurs first. The standard reporting period is currently expected to last six months, with an additional six months for qualifying small manufacturers reporting exclusively as article importers.

The delay follows EPA’s November 2025 proposal to narrow the rule through possible exemptions for imported articles, PFAS below a 0.1% concentration threshold, byproducts, impurities, research and development activities and non-isolated intermediates. These exemptions are not yet final.

For industry, the postponement provides useful preparation time but does not remove the need for due diligence. Companies should continue reviewing historical purchasing, import and formulation records, mapping PFAS-containing materials and requesting information from suppliers. The central difficulty remains the retrospective 12-year reporting period, particularly where article composition was not disclosed. Delaying preparation until the final rule is issued could leave businesses unable to assemble reliable data within the eventual submission window.