On November 13, 2025, the U.S. Environmental Protection Agency (EPA) announced multiple revisions to Toxic Substances Control Act (TSCA) reporting and recordkeeping requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS).
The EPA is proposing to narrow the scope of PFAS reporting and recordkeeping requirements by creating a series of exemptions for activities which would not yield any useful information. These exemptions include:
- A de minimis exemption in mixtures or articles with PFAS concentrations below 0.1%.
- PFAS imported as part of an article.
- PFAS manufactured as a byproduct, impurity, and non-isolated intermediary.
- PFAS manufactured in small quantities for research and development (R&D) purposes.
Advocacy supports the EPA’s revisions to the TSCA PFAS reporting and recordkeeping rule. The exemptions proposed by the EPA will reduce unnecessary regulatory costs for small entities while also allowing the EPA to meet its statutory obligations under TSCA. Advocacy also recommends the EPA publish compliance materials to help small entities understand the scope of the proposed exemptions.
COMMENT LETTER
Revisions to the PFAS Reporting and Recordkeeping Rule
(PDF, 250 KB)
CONTACT: Nick Goldstein
EMAIL: nick.goldstein@sba.gov
TOPIC(S): Letters to Agencies
TAG(S): EPA
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