On November 10, 2025, EPA released a proposed rule that would modify the one-time PFAS reporting requirement under the Toxic Substances Control Act (“TSCA”) section 8(a)(7). Comments on the proposed rule must be received by December 29, 2025.

In October 2023, EPA published a final rule requiring manufacturers (including importers) to submit certain information on PFAS manufactured or imported in any year between 2011 and 2022. EPA has since delayed this reporting on two occasions.

The proposed rule released on November 10 would incorporate certain exemptions and modifications. The modifications include further adjusting the reporting period to begin two months after the rule becomes effective and to last for three (rather than six) months. The proposed exemptions include the following, which are intended to target activities that manufacturers are least likely to know or be able to reasonably determine: 

• Reportable PFAS in mixtures or articles at concentrations below 0.1%; 

• PFAS imported as part of an article; 

• PFAS manufactured as byproducts, impurities, or non-isolated intermediates; and

• PFAS manufactured (including imported) in small quantities (i.e., quantities no greater than reasonably necessary) for research and development purposes.

The proposed rule and more information on submitting comments can be found here.