EPA Proposes Changes to PFAS Reporting Requirements

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The U.S. Environmental Protection Agency proposed revisions to the PFAS Data Reporting and Recordkeeping Rule under TSCA section 8(a)(7) on November 10, 2025, introducing exemptions and clarifications intended to reduce regulatory burden while maintaining the agency’s access to essential PFAS data. The proposal follows implementation challenges associated with the 2023 one-time PFAS reporting rule, including high compliance costs and difficulties faced by small businesses and importers.
According to the EPA, the proposed changes are designed to align reporting requirements with TSCA section 8(a)(5), focusing obligations on entities most likely to have relevant information and eliminating reporting for PFAS activities that manufacturers are unlikely to know or reasonably ascertain. The proposal would exempt PFAS manufactured, including imported, in mixtures or products at concentrations of 0.1% or lower, imported articles, certain byproducts, impurities, research and development substances, and non-isolated intermediates.
The EPA is also proposing technical corrections to clarify specific data fields and adjust the submission window to begin 60 days after the rule’s effective date, lasting for three months. These updates are intended to simplify reporting mechanics and ensure consistent submission of required information.
“This Biden-era rule would have imposed crushing regulatory burdens and nearly $1 billion in implementation costs on American businesses,” said EPA Administrator Lee Zeldin. “Today’s proposal is grounded in commonsense and the law, allowing us to collect the information we need to help combat PFAS contamination without placing ridiculous requirements on manufacturers, especially the small businesses that drive our country’s economy.”
The agency’s economic analysis estimates that the changes would reduce industry burden by 10–11 million hours and $786–843 million compared to the 2023 rule, while preserving the ability to collect PFAS data most relevant to environmental and health protection. Upon Federal Register publication, EPA will accept public comments for 45 days under docket EPA-HQ-OPPT-2020-0549.
Sources: EPA press release, EPA pre-publication notice
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