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EPA Delays PFAS Reporting Deadlines, Again: Implications for Manufacturers and Importers

By Jon Schaefer, Emilee Mooney Scott & Megan Baroni on May 19, 2025
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On May 12, 2025, the U.S. Environmental Protection Agency (EPA) announced an amendment delaying the data submission period for the Toxic Substances Control Act (TSCA) PFAS reporting rule, which will now begin on April 13, 2026, and end on October 13, 2026. Small manufacturers who report solely as article importers will have until April 13, 2027, to complete their submissions. The EPA stated that this delay is necessary to allow additional time for the development of the reporting software. While no other changes are currently planned, the agency is considering reopening certain aspects of the rule for public comment to accommodate potential modifications before the new deadlines.

The interim final rule, published in the Federal Register on May 13, 2025, became effective immediately but remains open for public comment for 30 days. This is the second delay in the reporting timeline. The original requirement was established in September 2023, mandating manufacturers and importers of PFAS from 2011 to 2022 to submit reports. Initially, the reporting period was scheduled to begin on July 11, 2025, but was postponed to accommodate ongoing preparations.

The initial rule aimed to impose reporting and recordkeeping requirements on entities involved in the manufacture or import of PFAS, including those in “articles,” as that term is defined by TSCA, for the years between 2011 and 2022. The EPA explained that delays are primarily due to the need for more time to develop necessary data collection tools and that the agency is considering future rule modifications influenced by efforts to deregulate, such as Executive Order 14219. The agency is also responding to petitions from chemical companies seeking to narrow the scope of the current rule and obtain exemptions consistent with standard TSCA 8(a) reporting provisions.

Photo of Jon Schaefer Jon Schaefer

I am a Partner in the Robinson+Cole’s Environmental, Energy + Telecommunications Group. I focus my practice on environmental compliance counseling, permitting, site remediation, occupational health and safety, energy regulatory compliance and siting, and litigation related to federal and state regulatory programs. My experiences…

I am a Partner in the Robinson+Cole’s Environmental, Energy + Telecommunications Group. I focus my practice on environmental compliance counseling, permitting, site remediation, occupational health and safety, energy regulatory compliance and siting, and litigation related to federal and state regulatory programs. My experiences working on complex matters for over a decade enable me to work effectively with experts and legal counsel to help clients minimize risk and solve compliance, enforcement, transactional, and regulatory matters. My full firm bio can be accessed here.

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Photo of Emilee Mooney Scott Emilee Mooney Scott

I am a Partner in the Environmental, Energy + Telecommunications Group. My practice focuses on assisting clients in complying with federal and state environmental laws, with a particular focus on the management of hazardous and toxic substances, especially under the Toxic Substances Control…

I am a Partner in the Environmental, Energy + Telecommunications Group. My practice focuses on assisting clients in complying with federal and state environmental laws, with a particular focus on the management of hazardous and toxic substances, especially under the Toxic Substances Control Act an the Emergency Planning and Community Right-to-Know Act. I also regularly help clients understand, manage, and limit environmental risk associated with business and property transactions, including assisting clients in complying with transaction-triggered compliance requirements like the Connecticut Transfer Act. My full bio is here.

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Photo of Megan Baroni Megan Baroni

I am a Partner in the Environmental, Energy + Telecommunications Group. I have extensive experience counseling clients on a wide variety of environmental, health, and safety issues. I frequently represent manufacturers and distributors and I am a contributing author to the firm’s Manufacturing …

I am a Partner in the Environmental, Energy + Telecommunications Group. I have extensive experience counseling clients on a wide variety of environmental, health, and safety issues. I frequently represent manufacturers and distributors and I am a contributing author to the firm’s Manufacturing Law Blog, focusing on environmental, health, and safety trends that will impact the industry. My full bio can be accessed here.

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  • Posted in:
    Environmental
  • Blog:
    Environmental Law +
  • Organization:
    Robinson & Cole LLP
  • Article: View Original Source

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