TSCA 8(a)(7)
May 27, 2026 | Written by GreenSoft Technology, Inc.
Current Status of the TSCA 8(a)(7) PFAS Reporting Rule
EPA Finalizes New Start Date for PFAS Reporting
On April 13, 2026, the Environmental Protection Agency (EPA) published the final rule in the Federal Register revising the start of the submission period for the TSCA 8(a)(7) PFAS Reporting Rule. Under the final rule, the PFAS reporting period, which was due to begin on April 13, 2026, will now begin on January 31, 2027 OR 60 days after the effective date of the forthcoming final rule, whichever is earlier.
Why did the EPA Issue Another Delay?
This marks another postponement in a series of delays since the rule was originally finalized in October 2023. The EPA is currently reviewing extensive public comments on the proposed rule revisions released in November 2025.
The Agency issued this postponement to ensure companies do not begin reporting under requirements that may soon change. The EPA emphasizes that the delay is intended to improve data quality, reduce unnecessary burden, and align reporting with the final amended rule.
The EPA describes January 31, 2027 as a backstop date to ensure the reporting period does not continue to slide while the Agency completes its revisions.
Submission Deadlines Remain the Same
Although the start date to the reporting period has shifted, the EPA has not changed the length of the submission windows:
- 6 month reporting period for most manufacturers and importers
- 12 month reporting period for small manufacturers reporting only as article importers
The EPA may revisit these timelines in the future, but for now, the existing windows remain in place. Companies should nonetheless be aware that the November 2025 proposed rule, if finalized, would shorten the reporting window for most manufacturers and importers from six months to three months.
So, while manufacturers have been given additional time to prepare for compliance with the TSCA Section 8(a)(7) PFAS reporting requirements, they still have a narrow window to finalize data collection and submit required reports. Companies should continue monitoring EPA updates closely.
Background: TSCA 8(a)(7) PFAS Reporting Requirements
Under the current TSCA Section 8(a)(7) reporting and recordkeeping requirements, any company that has manufactured or imported PFAS within the United States, or has imported PFAS-containing articles in any year between January 1, 2011 and December 31, 2022 are required to electronically report information regarding PFAS uses, production volumes, disposal, exposures, and hazards to the EPA.
These requirements were established in the October 11, 2023 final rule and remain in effect pending the EPA’s forthcoming rule revision.
Proposed TSCA PFAS Rule Revision: Category Exemptions and More
The forthcoming revision to the TSCA 8(a)(7) PFAS rule was published by the EPA on November 13, 2025. It aims to reduce regulatory reporting burdens for industry and exempt reporting on activities that manufacturers are least likely to know or reasonably determine.
The proposed category exemptions are:
- PFAS manufactured (including imported) in mixtures or products at concentrations 0.1% or lower;
- Imported articles;
- Certain byproducts;
- Impurities;
- Research and development chemicals; and
- Non-isolated intermediates.
The new proposal also offers several other key exemptions:
- It would remove the reporting requirement for imported articles, meaning most finished electronics and components containing trace PFAS would no longer be in scope.
- It also introduces a 0.1% concentration threshold, exempting mixtures and products with very small PFAS content.
This revision will be a significant change for Electrical and Electronic Equipment (EEE) producers and importers, as producers who have imported finished assemblies, components, or other articles (such as cables, housings, PCBs, etc.) between 2011 and 2023 would no longer be obligated to report PFAS content under TSCA Section 8(a)(7), effectively setting them out of scope for the EPA's TSCA PFAS reporting mandate. However, producers who have imported or produced raw PFAS chemicals or PFAS-containing mixtures would still be required to submit a report.
What Companies Should Do Now
Even with the new start date, companies should continue preparing for PFAS reporting. The EPA has made clear that the forthcoming revision will not eliminate the reporting obligation, only refine it.
Recommended next steps:
- Review historical PFAS manufacturing and import activity from 2011–2022
- Engage suppliers to obtain PFAS composition data
- Identify where proposed exemptions may apply
- Monitor EPA announcements as the rule revision approaches publication
GreenSoft Supports PFAS Data Collection and TSCA Reporting
GreenSoft Technology’s PFAS Data Services are design to help companies gather the supply chain chemical information required to meet TSCA 8(a)(7) PFAS reporting obligations.
Our experienced data collection team works directly with your suppliers to obtain detailed information on PFAS substances present in products and components, aligned with the PFAS definition established under TSCA Section 8(a)(7).
Companies can leverage GreenSoft’s Turnkey Service to have required compliance reports prepared on their behalf, or use the GreenData Manager software to centrally manage substance data and generate reports for TSCA and other global environmental regulations. Contact GreenSoft to learn more about how we can support your PFAS compliance efforts.
