On April 13, 2026, the U.S. Environmental Protection Agency (EPA) issued a final rule further delaying the start of the one-time data submission period for reporting per- and polyfluoroalkyl substances (PFAS) under Section 8(a)(7) of the Toxic Substances Control Act (TSCA). The rule postpones the opening of the reporting window until EPA completes a separate, forthcoming rulemaking addressing the substantive scope of the PFAS reporting requirements—or until January 31, 2027, if EPA does not finalize the rulemaking by that date.

This latest action follows a series of prior delays and reflects EPA’s ongoing reassessment of the breadth, burden, and implementation of its October 2023 PFAS reporting rule.

Background on the TSCA PFAS Reporting Rule

PFAS are sometimes referred to as “forever” chemicals because of their strong carbon-fluorine bonds that cause them to be extremely resistant to degradation in the environment. They have been used in a variety of products due to their resistance to degradation, their stability/non-reactivity, and the barrier they provide against water, oil, grease, and staining. Historically, PFAS have been used in a wide range of industrial and consumer products including the manufacture of textiles, food packaging, and as surfactants. They have also been used in firefighting foams used at airfields, refineries, and aboard ships.

Section 8(a)(7) of TSCA, added by the National Defense Authorization Act for Fiscal Year 2020, directs EPA to require reporting by any entity that manufactured (including imported) PFAS at any time since January 1, 2011.

EPA finalized its PFAS reporting and recordkeeping rule in October 2023. The rule adopts a broad, structural definition of PFAS, and requires manufacturers and importers to submit extensive historical information regarding PFAS identity, uses, production volumes, exposures, and health and environmental effects. As finalized, the rule imposes a one-time reporting obligation on entities that manufactured or imported PFAS—including PFAS imported in articles (i.e., manufactured goods or finished products)—for a commercial purpose between January 1, 2011, and December 31, 2022. The regulation has few exemptions and no de minimis threshold. This has created a significant compliance and planning burden across multiple industries.

In May 2025, EPA issued an interim final rule delaying the start of the reporting period to April 13, 2026. Under the interim rule, the end of the data submission period was pushed to October 13, 2026, or April 13, 2027, for certain small manufacturers reporting solely as article importers.  EPA explained that the delay was necessary to prepare the reporting application and to allow time to consider potential revisions to the rule, signaling that additional rulemaking would follow to address stakeholder concerns regarding reporting burden and feasibility.

EPA advanced substantive amendments to the PFAS reporting rule in November 2025, through a proposed rule modifying the scope of reportable activities. The proposed rule would establish several new reporting exemptions, including exemptions for de minimis concentrations of PFAS below 0.1%, PFAS imported as part of an article, and PFAS manufactured only as byproducts, impurities, or non-isolated intermediates. Under the proposed rule, the reporting submission period would begin 60 days after the final rule’s effective date and remain open for three months. EPA framed these changes as an effort to focus reporting on information that is reasonably ascertainable and most relevant to its regulatory objectives, while reducing industry compliance burdens compared to the broader October 2023 rule.

What EPA Changed in April 2026

EPA’s April 2026 final rule does not alter the scope of who must report or what information must be reported. Instead, it addresses only when reporting will begin.

Under the revised rule:

  • The PFAS reporting submission period will begin 60 days after the effective date of a forthcoming final rule addressing the substantive requirements of the PFAS reporting program; or
  • January 31, 2027, whichever occurs first.

EPA described January 31, 2027, as a backstop date and indicated that it expects to finalize the substantive revisions to the rule well before then. EPA also stated that it anticipates removing the backstop date in that future rulemaking.

The final rule leaves unchanged the duration of the submission period—six months for most reporters, with an additional six months for certain small manufacturers whose reporting obligations arise solely from article imports. EPA explained that any further adjustments to deadlines or reporting mechanics will be addressed in the forthcoming substantive revisions rule.

Why EPA Delayed Reporting Again

EPA cited several reasons for delaying the start of reporting. Since the interim final rule was issued in May 2025 and the proposed rule was issued in November 2025, the Agency has received thousands of comments regarding the need for exemptions for certain categories such as imported articles, low-concentration PFAS, impurities, byproducts, and research and development uses.

EPA also stated that delaying the reporting start date avoids requiring companies to expend resources compiling and submitting data that may not ultimately align with the final scope of the rule. The Agency further cited the need for additional time to finalize guidance and complete updates to its electronic reporting systems.

What This Means for Regulated Entities

For now, companies subject to the PFAS reporting rule do not need to submit any information and will not be required to report until EPA completes at least one more rulemaking (or until January 31, 2027, if EPA fails to finalize the rulemaking by that date). However, this delay does not eliminate the reporting obligation, and EPA has not yet finalized any substantive exemptions.

Companies that have already begun internal PFAS inventory efforts or supply chain inquiries may wish to reassess the pace and scope of those efforts while continuing to monitor EPA’s next steps. The substance of the forthcoming final rule—particularly whether EPA narrows the reporting universe—will determine the level of diligence ultimately required.

What to Watch Next

EPA has indicated that it will issue a separate final rule addressing the substantive revisions proposed in November 2025, including potential exemptions and clarifications to the reporting requirements. That rule will also establish the final reporting timeline.

Until then, the start of TSCA PFAS reporting remains on hold, but regulated entities should continue to track developments closely. We will continue to monitor EPA’s actions and provide updates as the PFAS reporting framework evolves.

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