TSCA PFAS Reporting Rule Tracker

General overview

• The government wants a full history of “forever chemicals.” A federal rule requires almost anyone who made or imported PFAS — or imported products containing them — since 2011 to report what they used, how much, and where it ended up. It’s a one-time look back over more than a decade.
• The start date keeps moving. It has been rescheduled repeatedly and now hangs on a rule EPA hasn’t published yet, with a hard backstop of January 31, 2027 if that rule doesn’t land first.
• The rules of the game may shrink mid-play. EPA has proposed exempting importers of finished goods and adding a small-quantity exemption. Nothing is final, so the wide version of the rule remains the law while the narrow one stays a proposal.
• States are moving on their own clocks. Minnesota’s PFAS reporting law reached its first deadline on September 15, 2026, untouched by the federal deferrals (extended filers have until December 14), and dozens of other states are legislating too.

What the rule requires

TSCA Section 8(a)(7), enacted by the FY2020 National Defense Authorization Act, directed EPA to collect data from every person who has manufactured or imported PFAS since 2011. The rule EPA promulgated on October 11, 2023 (40 CFR part 705) implements that statutory mandate as a one-time retrospective reporting obligation covering 2011–2022, requiring submission of chemical identity and structure, categories of use, production and processing volumes, byproducts, existing environmental and health effects information, worker exposure, and disposal. Because “manufacture” is defined under TSCA to include import — and EPA treats importers of PFAS-containing articles as manufacturers of PFAS — the rule as promulgated reaches well beyond chemical manufacturers to any entity that imported finished goods containing PFAS during the look-back period.

Who must report — the current rule and the proposed revision

Under the rule as promulgated, any person who manufactured or imported PFAS, or imported PFAS-containing articles, in any year from 2011 through 2022 is obligated to report, subject to no general de minimis concentration threshold. The proposed revision published November 13, 2025 would materially alter that framework: importers of finished articles would be exempted from the reporting obligation, and a de minimis exemption — absent from the current rule — would be introduced. Until EPA takes final action, however, the broader scope of the current rule remains controlling law, and regulated parties assessing the extent of their compliance obligations are weighing a proposal, not an operative exemption.

Procedural history — and its significance

The submission period has now been rescheduled on three occasions: from the original November 12, 2024 commencement, to July 11, 2025 (September 2024 direct final rule, citing delays in the reporting software), to April 13, 2026 (May 2025 interim final rule, which also established end dates of October 13, 2026, and April 13, 2027 for small article-importer-only reporters), to the present structure — 60 days after the effective date of the substantive final rule, backstopped by January 31, 2027 (April 13, 2026 final rule). EPA’s stated rationale for the most recent deferral is that it is reviewing the volume of comments on the November proposal so that regulated parties do not commence reporting under requirements that may subsequently change. The pattern is itself the point: the operative dates under this rule have not held, which is why a dated, change-logged tracker, rather than a point-in-time alert, is the appropriate instrument for monitoring it.

The triggering event: EPA’s forthcoming substantive final rule

The entire framework now turns on a single future Federal Register publication. When EPA finalizes the November 2025 proposal, it will simultaneously fix the commencement of the reporting period (60 days after the effective date, unless the January 31, 2027 backstop intervenes), resolve the article-importer and de minimis questions, and establish the duration of the submission window. EPA has represented that it intends to issue that rule later in 2026. This page will set out the full analysis when that rule publishes.

The Minnesota overlay

Minnesota’s Amara’s Law is the most consequential state PFAS reporting regime and operates on its own timeline, independent of EPA. Manufacturers of products containing intentionally added PFAS that are sold, offered for sale, or distributed in Minnesota — including sales made online into the state — must report product descriptions, the PFAS used, concentrations, and function, through MPCA’s PRISM system, subject to a one-time $800 reporting fee. The initial deadline, originally January 1, 2026, was extended to July 1 and thereafter — on April 15, 2026 — to September 15, 2026; MPCA reaffirmed that date on June 15, and it held. Manufacturers requiring additional time could request a one-time 90-day extension to December 14, 2026 (postmarked by August 16, 2026, subject to a $300 fee); that window has closed, and MPCA states it is processing a large volume of extension requests in the order received, with each applicant to receive a formal determination. A manufacturer granted an extension reports by December 14, 2026; one denied an extension reports 30 days after the notice of denial or by September 15, 2026, whichever is later. Subsequent reports and updates to previous reports, when required, are due each year on February 1. A June 2026 amendment (2026 Minn. Laws, ch. 127, art. 14, § 4) narrowed the scope of the obligation to products manufactured after July 1, 2023. For this first reporting cycle, MPCA has stated that it will treat a manufacturer as compliant provided it timely reports all available information and documents its supplier due diligence. The statutory endpoint is unchanged: intentionally added PFAS are prohibited in nearly all products effective January 1, 2032, absent a currently-unavoidable-use determination.

How companies are preparing

Guidance from law firms and the compliance industry converges on a common posture: continue PFAS inventory and supplier-outreach work notwithstanding the federal deferral, because the look-back extends to 2011 and data assembly remains the long pole irrespective of where the scope ultimately lands; document due diligence, particularly for Minnesota’s first reporting cycle; and monitor the article-importer exemption, as it will determine whether large categories of importers fall within or outside the federal rule entirely. Regbase reports these observable postures; it does not advise upon them.

FAQ

When does federal PFAS reporting actually commence? On the earlier of 60 days after the effective date of EPA’s forthcoming substantive final rule or January 31, 2027. EPA has represented that it intends to finalize later in 2026 and anticipates removing the backstop date in that action.

Has the reporting obligation been eliminated? No. EPA has represented that the pending revision will refine the requirement, not remove it. The deferrals affect timing only.

Are article importers still covered? Under the current rule, yes — importers of PFAS-containing articles are treated as manufacturers. The November 2025 proposal would exempt importers of finished articles, but that exemption is proposed, not final.

Is there a de minimis threshold? Not under the current rule. A new de minimis exemption forms part of the pending proposal.

What years does the report cover? Manufacture or import in any year from January 1, 2011 through December 31, 2022.

What was due September 15, 2026? Initial reports under Minnesota’s Amara’s Law — a separate state obligation covering intentionally added PFAS in products sold into Minnesota, unaffected by the federal deferral. The window to request a 90-day extension to December 14 closed August 16. Manufacturers granted an extension report by December 14, 2026; those denied report 30 days after the notice of denial or by September 15, whichever is later.

Could the federal date move a fifth time? The backstop structure is designed to preclude that outcome — January 31, 2027 holds even if the substantive rule slips — but EPA has represented that it anticipates removing the backstop in the final rule, such that the operative date will be whatever that rule prescribes. Any change will be logged here, with the primary source attached.

Changelog

• September 16, 2026 — The submission period has been rescheduled on three occasions, per the rulemaking record. The sequence: the original November 12, 2024 commencement, the September 2024 direct final rule moving it to July 11, 2025, and the April 13, 2026 final rule establishing the present trigger-based commencement. The “At a glance” row and the procedural-history section below now state three. Also adds Minn. R. 7026.0100, subp. 4 to the primary sources for the extension fee — the rule that sets it (“A manufacturer that submits an extension request under part 7026.0060 must pay a $300 fee”), rather than 7026.0060, which only cross-references it. Not re-checked this pass: the federal submission-window dates, the Minnesota reporting requirements and the fee amounts, all carried forward unchanged.
• September 15, 2026 — Minnesota’s initial reporting deadline arrived; still no federal change. Minnesota: MPCA’s reporting page, re-read on the deadline date, continues to state that initial Amara’s Law reports are due by September 15, 2026, with no further postponement announced. It also sets the due date for manufacturers denied an extension — 30 days after the notice of denial or September 15, whichever is later — which this page now reports alongside the December 14 date for granted extensions; MPCA states it is still processing extension requests. The overlay now also notes MPCA’s annual February 1 date for subsequent reports and updates, when required. Deadline language in the description, pill, summary, overlay, at-a-glance, and FAQ moved out of future tense. Federal: no EPA action on the TSCA 8(a)(7) rule has published in the Federal Register since the September 2 check (FR API: 31 EPA documents published September 2–15, none matching PFAS), and EPA’s program page — still last updated April 16, 2026 — continues to describe the substantive final rule as “expected in 2026.” The trigger-based commencement and the January 31, 2027 backstop are unchanged.
• September 2, 2026 — Re-verified with no federal change; Minnesota’s extension window closed. Federal: no EPA action on the TSCA 8(a)(7) rule has published in the Federal Register since the April 13, 2026 final rule (checked via the FR API for EPA rules and proposed rules since July 13), and EPA’s program page — last updated April 16, 2026 — still describes the substantive final rule as “expected in 2026.” The trigger-based commencement and the January 31, 2027 backstop are unchanged. Minnesota: MPCA’s reporting page confirms initial Amara’s Law reports remain due September 15, 2026; the August 16 postmark deadline for one-time 90-day extension requests has passed, and MPCA reports it is processing a large volume of requests in the order received. Extension language on this page moved to past tense accordingly. No other state reporting deadline on this page changed.
• July 13, 2026 — Accuracy and format pass. Procedural language tightened throughout (submission-period commencement, deferral history); proposed de minimis thresholds specified (0.1%, with comment solicited on a 1.0% alternative); 2026 state-bill counts updated (nearly 100 newly introduced across 17 states, atop roughly 280 carried over across 23); plain-English summary section added.
• July 8, 2026 — Page launched. Current status: submission period deferred to 60 days after the effective date of EPA’s forthcoming substantive final rule (or the January 31, 2027 backstop) per the April 13, 2026 final rule; November 2025 scope-revision proposal under review (comment period closed Dec 29, 2025). State side: MPCA reaffirmed the September 15, 2026 Amara’s Law deadline on June 15; June 2026 amendment excludes products manufactured before July 1, 2023.

Primary sources: EPA final rule, April 13, 2026 (Federal Register) · EPA TSCA 8(a)(7) program page · MPCA — Reporting PFAS in products · Minn. R. 7026.0100, subp. 4 (extension fee)