EPA recently published an interim final rule delaying by nine months the time for manufacturers and importers of products containing perfluoroalkyl or polyfluoroalkyl substances (PFAS) to report to EPA on their past activities. EPA’s PFAS reporting rule requires anyone who manufactured (including imported) any PFAS compound, or who imported any article containing a PFAS compound, at any time between 2011 and 2022, to submit detailed information regarding those past activities. The rule published on May 13, 2025, postpones the start of the reporting period from July 11, 2025, to April 13, 2026. Reporting must now be completed by October 13, 2026, for most manufacturers and by April 13, 2027, for small manufacturers reporting exclusively as article importers.
As we have previously described, the PFAS reporting rule applies to companies in the automotive and aerospace industries, who frequently utilize fluoropolymers (which EPA has included within the definition of PFAS) for parts such as gaskets, tubing, electrical wiring, composite materials, and printed circuit boards. The PFAS reporting rule does not contain exemptions for PFAS in such articles. There is, however, a possibility that that may change. Although “EPA is not amending any other aspects of the regulation at this time,” the Agency is considering a separate notice‑and‑comment rulemaking to potentially modify other portions of the PFAS reporting rule, which may include responses to industry requests for exemptions for imported articles.
Even though the federal PFAS reporting deadlines have been delayed for nine months, Minnesota’s PFAS reporting mandate remains set to take effect on January 1, 2026. This state-level requirement will significantly impact manufacturers and importers by requiring detailed disclosures about products containing intentionally added PFAS that are sold, offered for sale, or distributed for sale in Minnesota.