Starting in July 2025, the EPA is requiring new reporting under the Toxic Substances Control Act (TSCA) Section 8(a)(7) related to PFAS (Per- and Polyfluoroalkyl Substances). This is a significant update on PFAS Reporting Requirements that affects manufacturers, importers, and even businesses dealing with products that may contain PFAS—including solid articles like coated materials or components. The reporting scope is broad, covering a generic definition of PFAs and includes use dating back to January 1, 2011. If your business has manufactured or imported PFAS or PFAS-containing products in that time, it’s essential to start preparing now.
Here’s What You Need to Know:
- Determine Applicability
Begin by assessing whether your company has handled PFAS directly or indirectly. This includes reviewing product formulations, purchasing records, and your supply chain. Remember, PFAS were commonly used as coatings, and many items may contain them even if they’re not chemicals with associated SDSs. - Gather Required Data
You’ll need to collect details such as:• Chemical identity
• Production or import volumes
• Uses of the substances
• Environmental and health effects (if known)Engage with your vendors and suppliers now to begin pulling together this information.
- Use EPA’s CDX System
All reports must be submitted electronically via the EPA’s Central Data Exchange (CDX) system. - Complete the TSCA Reporting Form
Make use of EPA’s guidance materials to accurately complete the required forms. - Submit Before the Deadline
• Standard businesses must submit by January 11, 2026
• Small businesses have until July 11, 2026 - Retain Records
Keep copies of all reports and supporting documentation for at least five years after submission.
Key Considerations:
PFAS reporting is not just for your EH&S team. A multidisciplinary approach is crucial—PFAS may appear in unexpected places, including:
• IT components
• Maintenance materials (indoor and outdoor)
• Building construction materials
• Firefighting gear or coatings
Importantly, no laboratory testing is required, but EPA expects businesses to document reasonable efforts to locate information. Even if you can’t find everything, tracking and showing your search process is critical to demonstrating compliance. Please call us if you need help with a game plan and assistance for 2025 PFAS TSCA reporting requirements.
Click below for easy to follow Reporting Requirement Guides:
