What: On November 13, 2025, the U.S. Environmental Protection Agency (EPA) proposed revisions to the Toxic Substances Control Act (TSCA) reporting requirements for perfluoroalkyl and polyfluoroalkyl substances (PFAS).
Why: EPA’s original PFAS reporting requirements were issued in 2023. No data has been submitted under the original rule because the compliance date has been extended twice. The current submission deadline is April 13, 2026.
EPA is proposing to add exemptions to the PFAS reporting requirements, including:
- A de minimis exemption of 0.1%.
- Imported articles.
- Byproducts.
- Impurities.
- Research & development.
- Non-isolated intermediates.
In addition to the new exemptions, EPA is also seeking comments on the scope of reportable chemicals and the economic analysis of its proposed rule changes.
The following industries may be impacted by EPA’s proposal:
- Testing Laboratories (NAICS code 541380).
- Research and Development in the Physical, Engineering, and Life Sciences (except Nanotechnology and Biotechnology) (NAICS codes 541715 or 541710).
- Hazardous Waste Treatment and Disposal (NAICS code 562211).
- Solid Waste Combustors and Incinerators (NAICS code 562213).
- Colleges, Universities, and Professional Schools (NAICS code 611310).
- Medical and Diagnostic Laboratories (NAICS codes 621511 or 621999).
Action: Comments are due December 29, 2025.
PROPOSED RULE:
PFAS Data Reporting and Recordkeeping Under the TSCA; Revision to Regulation
ORIGINAL PFAS REPORTING REQUIREMENTS:
CONTACT:
Nick Goldstein
EMAIL:
Regulatory Alerts
TAG(S):
EPA
Is your small business or entity being impacted by a proposed rule? If yes, write a comment letter to the proposing agency.