TSCA PFAS Reporting: 2026 Guide
TSCA PFAS Reporting is becoming one of the most important chemical compliance obligations for companies placing products, articles, chemicals, mixtures, or materials on the U.S. market.
Under TSCA Section 8(a)(7), EPA finalized reporting and recordkeeping requirements for PFAS. The rule requires certain manufacturers and importers, including companies that imported PFAS-containing articles, to report information to EPA for PFAS manufactured or imported in any year since January 1, 2011. EPA states that reportable information includes PFAS uses, production volumes, disposal, exposures, and hazards.
For companies, the challenge is not only understanding the regulation. The bigger challenge is finding reliable product, material, supplier, and historical import data across complex supply chains.
This guide explains the latest TSCA PFAS Reporting updates, who may need to report, what information companies should collect, what deadlines matter, how to manage supplier evidence, and how ComplyMarket product compliance software can help companies prepare.
What companies need to know
TSCA PFAS Reporting requires certain companies that manufactured or imported PFAS, including PFAS-containing articles, in any year since January 1, 2011, to report data to EPA.
The current reporting start date is January 31, 2027, or 60 days after the effective date of EPA’s forthcoming final rule on the substantive reporting requirements, whichever is earlier.
Companies should not wait for the reporting window to open. They should use the available time to:
- Identify products, articles, mixtures, and materials that may contain PFAS
- Review historical U.S. manufacturing and import activity from 2011 onward
- Collect supplier PFAS declarations, SDS files, material declarations, and technical evidence
- Map PFAS information to products, suppliers, sites, and years
- Prepare internal reporting logic and recordkeeping files
- Monitor EPA’s final rule updates before submission
Why TSCA PFAS Reporting matters
PFAS are widely discussed because of their persistence, potential exposure concerns, and increasing regulatory scrutiny. For companies, TSCA PFAS Reporting creates a practical supply chain data obligation.
A company may need to answer questions such as:
- Did we manufacture or import PFAS at any point since January 1, 2011?
- Did we import articles that contained PFAS?
- Which products, components, coatings, textiles, formulations, or materials may be affected?
- Which suppliers can provide evidence?
- Do we have historical import and volume data?
- What information is known or reasonably ascertainable?
- What should we report, and what should we document internally?
EPA’s rule is not limited to current products only. It requires companies to look back at historical activity, which can make data collection difficult for discontinued products, legacy suppliers, old materials, and past import records.
Latest TSCA PFAS Reporting updates for 2026
EPA finalized the TSCA PFAS reporting rule in October 2023. In April 2026, EPA finalized a change to the start of the reporting period. The submission period will now begin on January 31, 2027, or 60 days following the effective date of a forthcoming final rule on the substantive requirements, whichever is earlier.
EPA also proposed changes to the scope of the TSCA PFAS reporting regulations in November 2025. EPA states that the proposed changes include exemptions and modifications intended to reduce unnecessary or duplicative reporting requirements. These proposed exemptions include PFAS in mixtures or products at concentrations of 0.1% or lower, imported articles, certain byproducts, impurities, research and development chemicals, and non-isolated intermediates.
The key point for companies is this: proposed exemptions are not final until EPA completes the final rulemaking process. Companies should continue preparing data and evidence until the final scope is confirmed.
Key TSCA PFAS Reporting dates
|
Topic |
Current status |
|
Final rule |
EPA finalized TSCA Section 8(a)(7) PFAS reporting and recordkeeping requirements on October 11, 2023. |
|
Historical lookback period |
EPA states that the rule applies to PFAS manufactured or imported in any year since January 1, 2011. |
|
Current reporting start |
The reporting period begins on January 31, 2027, or 60 days after the effective date of EPA’s forthcoming final substantive rule, whichever is earlier. |
|
Standard submission period |
EPA states that when the submission period begins, manufacturers will have six months to provide their data. |
|
Article importer / small manufacturer timing |
Current eCFR text provides a twelve-month submission period for small manufacturers reporting exclusively as article importers. |
|
Proposed scope changes |
EPA proposed revisions in November 2025, including possible exemptions for imported articles and other categories, but these should not be treated as final yet. |
Who may need to report?
TSCA PFAS Reporting may apply to companies that manufactured or imported PFAS for a commercial purpose during the rule’s lookback period. EPA’s reporting instructions state that reporting is required for manufacturers, including importers, of PFAS manufactured or imported for commercial purposes during the lookback period.
Potentially affected companies may include:
|
Company type |
Why it may be affected |
|
Chemical manufacturers |
PFAS may have been manufactured directly or formed as part of chemical manufacturing activities. |
|
Importers |
Under TSCA, manufacture includes import, so import activity can trigger reporting obligations. |
|
Article importers |
Current rules include streamlined reporting options for importers of articles containing PFAS. |
|
Finished goods brands |
PFAS may be present in coatings, textiles, electronics, packaging, components, or supplier materials. |
|
Distributors and private-label sellers |
Historical import responsibility may need to be reviewed. |
|
Procurement and supplier management teams |
Supplier declarations and supporting evidence may be needed to determine reportability. |
|
Compliance and legal teams |
Internal decisions, data gaps, confidentiality claims, and evidence files need to be documented. |
This is why TSCA PFAS Reporting should not be viewed only as a chemical manufacturer issue. It may also affect companies importing finished products, parts, components, or articles into the United States.
What counts as PFAS under the rule?
EPA defines PFAS for this reporting rule using a structural definition. EPA states that “PFAS” refers to chemical substances that meet the structural definition codified at 40 CFR 705.3.
This matters because companies cannot rely only on common PFAS names. PFAS may appear under:
- CAS numbers
- Trade names
- Proprietary mixture names
- Confidential chemical identities
- Supplier-specific material descriptions
- Fluoropolymer or fluorochemical terminology
- Coating, treatment, membrane, or additive descriptions
For complex products, technical review may be needed to determine whether a substance meets EPA’s PFAS definition.
What information must be reported?
EPA states that reportable information includes PFAS uses, production volumes, disposal, exposures, and hazards.
The eCFR states that reporting must be submitted to the extent the information is known to or reasonably ascertainable by the submitter. If actual data is not known or reasonably ascertainable, reasonable estimates may be submitted.
Companies should prepare to collect and organize the following information:
|
Data category |
Examples of information to collect |
|
Company and site information |
Legal entity, U.S. parent company, reporting site, technical contact, authorized official |
|
PFAS identity |
CAS number, chemical name, trade name, generic name, molecular identity, supplier-provided identity |
|
Product and article mapping |
Products, components, materials, mixtures, articles, coatings, and formulations that may contain PFAS |
|
Use information |
Industrial, commercial, or consumer use; product category; function of PFAS |
|
Historical activity |
Manufacturing, importing, processing, or article import activity from 2011 onward |
|
Volume information |
Production volume, import volume, article volume, or reasonable estimates |
|
Concentration information |
Known or estimated PFAS concentration in products, articles, materials, or mixtures |
|
Supplier evidence |
Supplier declarations, SDS, full material declarations, technical datasheets, test reports |
|
Exposure information |
Worker exposure, consumer exposure, commercial exposure, and relevant use conditions |
|
Disposal and release information |
Waste handling, disposal methods, byproducts, releases, recycling, incineration, or landfill information |
|
Health and environmental information |
Existing studies or information known to or reasonably ascertainable by the company |
What does “known or reasonably ascertainable” mean?
The eCFR defines “known to or reasonably ascertainable by” as information in a person’s possession or control, plus information that a reasonable person in a similar situation might be expected to possess, control, or know.
For companies, this means a practical review should go beyond one internal spreadsheet. Relevant information may sit across several departments and systems.
|
Information source |
Why it matters |
|
Bills of materials |
Helps identify components, parts, coatings, materials, and assemblies |
|
Supplier declarations |
Provides supplier-level evidence of PFAS presence, absence, or unknown status |
|
SDS files |
Supports chemical and mixture review |
|
Full Material Declarations |
Helps assess substance-level composition |
|
Import records |
Supports historical review of articles and products entering the U.S. |
|
Purchase records |
Helps identify suppliers, materials, and historical sourcing |
|
Engineering specifications |
May reveal PFAS-related performance requirements such as chemical resistance, oil resistance, or water resistance |
|
Technical datasheets |
May identify coatings, membranes, lubricants, seals, or additives |
|
Test reports |
Can support high-risk material investigation |
|
Supplier correspondence |
Documents due diligence and unresolved information gaps |
A strong compliance process should document what was reviewed, who was contacted, what was received, what remains unknown, and why a conclusion was reached.
Important: Proposed exemptions are not final yet
EPA’s November 2025 proposal includes possible exemptions and modifications for several categories, including:
- PFAS manufactured or imported in mixtures or products at concentrations of 0.1% or lower
- Imported articles
- Certain byproducts
- Impurities
- Research and development chemicals
- Non-isolated intermediates
EPA describes these as proposed changes to the TSCA Section 8(a)(7) PFAS reporting regulations.
Companies should not assume that a proposed exemption already applies. Until EPA publishes the final revisions, compliance teams should continue preparing PFAS data, supplier evidence, and internal decision records.
A practical approach is to classify each product, material, or supplier record as:
|
Status |
Meaning |
|
Confirmed reportable |
Evidence indicates PFAS activity that may need to be reported |
|
Potentially reportable |
PFAS risk exists, but more supplier or technical data is needed |
|
Pending final rule |
A proposed exemption may apply, but final EPA confirmation is needed |
|
Not reportable based on evidence |
Documentation supports a conclusion that reporting is not required |
|
Unknown / data gap |
Information is missing and additional due diligence is needed |
Are imported articles covered?
Under the current rule, article importers are addressed in the reporting framework. The eCFR includes a streamlined reporting option for importers of articles containing PFAS, and it requires article importers to submit information to the extent they know or can reasonably ascertain it.
However, imported articles are also included in EPA’s November 2025 proposed exemptions.
This creates an important compliance point: article importers should continue preparing until EPA finalizes the scope. Even if an exemption becomes final, supplier PFAS data may still be needed for customer requests, U.S. state PFAS laws, retailer requirements, restricted substance lists, and international product compliance.
Are small manufacturers exempt?
EPA’s reporting instructions state that no small manufacturer exemptions are in effect for this data call. EPA notes that companies may be required to report under the PFAS data call even if they are not required to report under other TSCA requirements, such as Chemical Data Reporting, due to a small manufacturer exemption.
This means company size alone should not be used as the basis for ignoring TSCA PFAS Reporting. Applicability should be assessed based on activity, product scope, import status, PFAS presence, and EPA’s final rule requirements.
How companies should collect supplier PFAS data
Supplier engagement is one of the most important steps in TSCA PFAS Reporting preparation. Many companies will not have complete PFAS information internally, especially for complex products, imported articles, or historical materials.
A supplier request should be specific and evidence-based. Instead of asking only “Is this product compliant?”, companies should request information such as:
|
Supplier data request |
Why it matters |
|
PFAS presence or absence declaration |
Helps determine whether PFAS may be present in a product, article, material, or mixture |
|
Affected part numbers |
Connects the declaration to the correct product scope |
|
Chemical identity |
Supports substance-level review and reporting |
|
CAS number or generic identity |
Helps address reportability and confidential identity issues |
|
Concentration range |
Supports reporting and risk prioritization |
|
Function of PFAS |
Explains why PFAS is used, such as coating, lubricant, membrane, additive, or surface treatment |
|
Historical supply period |
Helps assess whether the material was supplied during the lookback period |
|
SDS or technical datasheet |
Supports chemical and mixture review |
|
Full Material Declaration |
Provides more complete material-level evidence |
|
Reformulation statement |
Helps identify whether PFAS was removed or replaced over time |
|
Authorized signature |
Improves accountability and evidence quality |
Supplier data should also be reviewed for quality. A generic declaration that does not mention specific products, materials, part numbers, or dates may not be strong enough for a historical reporting assessment.
Product and material categories that may need closer PFAS review
PFAS may be used for performance characteristics such as water resistance, oil resistance, stain resistance, grease resistance, chemical resistance, heat resistance, weather resistance, non-stick properties, or low friction.
The following categories should not be treated as automatically containing PFAS, but they may deserve closer review:
|
Product or material area |
Why it may be relevant |
|
Textiles, apparel, footwear, upholstery |
PFAS may be used in water, oil, or stain-resistant finishes |
|
Electronics and electrical equipment |
PFAS may appear in insulation, cables, membranes, coatings, or processing applications |
|
Automotive and industrial components |
PFAS may be used in seals, gaskets, hoses, lubricants, coatings, and high-performance polymers |
|
Packaging and food-contact materials |
Some applications may involve grease-resistant or barrier properties |
|
Cookware and kitchen products |
Non-stick or heat-resistant surfaces may require review |
|
Chemical mixtures and formulations |
PFAS may be intentionally added or present in certain formulations |
|
Medical and laboratory materials |
Specialized tubing, membranes, filters, or chemical-resistant parts may need assessment |
|
Construction products |
Coatings, membranes, sealants, or treated surfaces may be relevant |
|
Firefighting-related materials |
Certain technical materials and foams may involve PFAS concerns |
A risk-based screening process helps companies prioritize supplier outreach and evidence collection.
What if PFAS information is missing?
Information gaps are common, especially for older products, discontinued parts, legacy suppliers, or confidential chemical identities.
Companies should avoid undocumented assumptions. If information is missing, the company should document reasonable inquiry and explain the basis for any conclusion.
|
Situation |
Recommended action |
|
Supplier does not respond |
Send follow-up requests and document contact dates, recipients, and unanswered questions |
|
Supplier provides a vague declaration |
Request product-specific, part-specific, and date-specific clarification |
|
Supplier claims confidentiality |
Ask whether a generic name, joint submission, or direct EPA submission pathway may be appropriate |
|
Historical supplier no longer exists |
Review legacy SDS files, purchase records, import records, specifications, and internal databases |
|
Product was discontinued |
Confirm whether it was manufactured or imported during the lookback period |
|
Exact concentration is unknown |
Use supplier information, technical assessment, reasonable estimates, or testing where appropriate |
|
PFAS risk is high but evidence is weak |
Consider targeted testing or expert chemical review |
The goal is to show a clear and reasonable compliance process.
TSCA PFAS recordkeeping requirements
Recordkeeping is not optional. The eCFR states that each person subject to the reporting requirements must retain records documenting the information reported to EPA for 5 years beginning on the last day of the submission period.
A strong recordkeeping file should include:
|
Record type |
Purpose |
|
Product scope list |
Shows which products, articles, materials, and mixtures were assessed |
|
Supplier request log |
Documents outreach and follow-up activity |
|
Supplier declarations |
Supports presence, absence, unknown, or restricted-information conclusions |
|
SDS and technical documents |
Supports chemical identity and formulation review |
|
Full Material Declarations |
Supports substance-level evidence |
|
Import and production records |
Supports historical activity and volume calculations |
|
Risk assessment notes |
Explains why certain materials were prioritized |
|
Test reports |
Supports conclusions for high-risk or uncertain materials |
|
Internal decision log |
Documents reportable, not reportable, pending, and unknown items |
|
Final reporting file |
Supports EPA submission and future audits |
Practical TSCA PFAS Reporting readiness workflow
|
Step |
Action |
Business output |
|
1 |
Define the reporting scope |
List U.S. entities, sites, product lines, imported articles, chemicals, and mixtures |
|
2 |
Map historical activity |
Identify manufacturing and import activity from 2011 onward |
|
3 |
Prioritize PFAS risk areas |
Focus on high-risk materials, coatings, treatments, and formulations |
|
4 |
Launch supplier data requests |
Collect declarations, SDS files, FMDs, technical datasheets, and supporting evidence |
|
5 |
Review chemical identity |
Determine whether substances meet EPA’s PFAS definition |
|
6 |
Link data to products |
Connect PFAS evidence to product numbers, suppliers, sites, years, and volumes |
|
7 |
Assess data gaps |
Identify unknown, missing, confidential, or not reasonably ascertainable information |
|
8 |
Prepare reporting logic |
Classify items as reportable, potentially reportable, not reportable, or pending final rule |
|
9 |
Build evidence files |
Organize documentation for reporting and recordkeeping |
|
10 |
Monitor EPA updates |
Update the assessment when EPA finalizes substantive rule revisions |
Common mistakes to avoid
|
Mistake |
Why it creates risk |
|
Waiting until the reporting window opens |
Supplier data collection can take months, especially for complex supply chains |
|
Assuming imported articles are already exempt |
Imported articles are part of a proposed exemption, but proposed changes are not final yet |
|
Reviewing only current products |
The rule has a historical lookback period going back to January 1, 2011 |
|
Asking suppliers vague questions |
Generic compliance confirmations may not support TSCA PFAS reporting decisions |
|
Ignoring discontinued products |
Legacy products may still fall within the lookback period |
|
Keeping evidence in scattered emails |
Reporting and recordkeeping require traceable documentation |
|
Treating “unknown” as enough |
Companies should document reasonable inquiry and data gap management |
|
Forgetting volume and use data |
Reporting may require more than PFAS presence or absence information |
FAQ: TSCA PFAS Reporting
What is TSCA PFAS Reporting?
TSCA PFAS Reporting is EPA’s reporting and recordkeeping requirement under TSCA Section 8(a)(7). It requires certain manufacturers and importers of PFAS, including PFAS-containing articles, to electronically report information to EPA.
Who must report under TSCA PFAS?
Companies that manufactured or imported PFAS for commercial purposes during the lookback period may need to report. This can include chemical manufacturers, importers, and article importers, depending on the final scope and available evidence.
What is the TSCA PFAS Reporting deadline?
The reporting period is currently set to begin on January 31, 2027, or 60 days after the effective date of EPA’s forthcoming final substantive rule, whichever is earlier.
Do article importers need to prepare?
Yes. Current rules include article importer reporting provisions and streamlined reporting options. EPA has proposed an imported article exemption, but companies should not treat that proposal as final until EPA completes the final rulemaking.
Is there a small manufacturer exemption?
EPA’s reporting instructions state that no small manufacturer exemptions are in effect for this PFAS data call.
What data should companies collect?
Companies should collect supplier declarations, SDS files, full material declarations, product and article mapping, PFAS identity information, use information, volume data, exposure information, disposal information, and supporting evidence.
How long should records be kept?
Records documenting information reported to EPA must be retained for 5 years beginning on the last day of the submission period.
Should companies wait for the final EPA revisions before preparing?
No. Companies should monitor the final rule, but they should begin preparing product mapping, supplier evidence, and internal records now. Waiting may create unnecessary pressure when the reporting window opens.
How ComplyMarket product compliance software can help
TSCA PFAS Reporting is not only a regulatory filing task. It is a supplier data, material compliance, traceability, and evidence management challenge.
ComplyMarket’s PFAS Compliance & Reporting Software is designed to help companies manage PFAS compliance through material risk assessment, supplier engagement, digital declarations, regulatory checks, and reporting support. ComplyMarket states that its platform helps companies simplify PFAS compliance, automate supplier reporting, assess material risk, and manage PFAS attestations.
For companies preparing for TSCA PFAS Reporting, ComplyMarket can help in several practical ways.
1. Supplier PFAS data collection
ComplyMarket can support structured supplier engagement, helping companies request and collect PFAS declarations, supplier attestations, material information, SDS files, and supporting documentation.
This helps reduce manual follow-up and improves the consistency of supplier responses.
2. Product and material traceability
Companies need to link PFAS information to products, components, suppliers, materials, sites, and reporting years. ComplyMarket helps organize this information in one compliance workflow so teams can understand where PFAS risk exists and which evidence supports each decision.
3. Material risk assessment
ComplyMarket describes material risk scoring and AI material risk assessment as part of its PFAS compliance capabilities.
This can help companies prioritize high-risk materials and focus supplier outreach where it matters most.
4. Digital declarations and evidence management
ComplyMarket provides a central hub to collect, manage, and audit supplier PFAS attestations.
For TSCA PFAS Reporting, this supports better recordkeeping, clearer documentation, and easier internal review.
5. Multi-regulation compliance coverage
PFAS compliance is not limited to one EPA rule. Companies may also face U.S. state PFAS requirements, customer requirements, restricted substance lists, and international product compliance obligations. ComplyMarket states that its platform supports automatic checks for PFAS, REACH, RoHS, TSCA, POPs, and more.
This allows companies to use PFAS data for broader compliance needs, not only TSCA reporting.
6. Reporting readiness before the EPA window opens
The updated reporting timeline gives companies more time, but it does not remove the need to prepare. ComplyMarket helps companies move from scattered supplier emails and spreadsheets to a structured, traceable PFAS compliance process.
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