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 runs on a September 15, 2026 deadline the federal deferrals don’t touch, 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 four 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. Manufacturers requiring additional time may request a one-time 90-day extension to December 14, 2026 (postmarked by August 16, 2026, subject to a $300 fee). 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 with respect to Minnesota’s September deadline; 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 is 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. A 90-day extension to December 14 is available if requested by August 16.

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

• 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