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US EPA Requests Comments for TSCA PFAS Reporting

Dec. 15 2025

The US Environmental Protection Agency (EPA) released a request for public comment related to revisions on the Toxic Substances Control Act (TSCA) 8(a)(7), PFAS reporting. Comments are due on or before December 29, 2025.

Key Revisions Proposed in the Draft Rule

• The proposed rule exempts:
      o imported articles containing PFAS,
      o PFAS in mixtures or articles below 0.1% (a “de minimis” exemption),
      o manufacture of PFAS as by-products, impurities, and non-isolated intermediates, and
      o manufacture (including import) of PFAS in small quantities for R&D purposes.

• Imported articles containing PFAS are being considered for exemption since the EPA feels this is likely an area where it would be difficult to obtain the required data and information for the timeframe (2011-2022) of reporting.

• Additional changes have been proposed related to the information to be reported, as well as the category names listed in the rule.

Comments are due by December 29, 2025 for anyone who wishes to provide feedback.

For more information, see link for full details:
• US EPA, Proposed Rule, 40 CFR Part 705, Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Revision to Regulation
https://www.govinfo.gov/content/pkg/FR-2025-11-13/pdf/2025-19882.pdf

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