On November 10, 2025, the U.S. Environmental Protection Agency (EPA) proposed major revisions to PFAS reporting requirements under the Toxic Substances Control Act (TSCA). Under the draft rule, manufacturers would no longer be required to submit detailed data for four key categories: low-concentration PFAS, imported articles, byproducts/impurities, and small-scale R&D uses.
Background
In October 2023, the Biden administration introduced a mandatory PFAS reporting rule under TSCA Section 8(a)(7), requiring companies that manufactured or imported PFAS from 2011 to 2022 to report exposure-related and environmental data. The rule quickly drew criticism due to:
· Estimated compliance costs nearing $1 billion
· Unclear frameworks for how EPA would use the data
· IT system failures and administrative delays
· Significant reporting burdens on small businesses and importers
The newly proposed revisions aim to streamline requirements while preserving essential PFAS oversight.
Key Proposed Exemptions
· Low-concentration exemption: PFAS in mixtures or articles below 0.1% would not require reporting.
· Imported article exemption: Importers of PFAS-containing articles would be exempt.
· Byproducts, impurities, non-isolated intermediates exemption: PFAS formed unintentionally during production would be excluded.
· R&D exemption: Small-scale research-related PFAS uses would not require reporting.
Revised Reporting Timeline
Reporting would open 60 days after the final rule takes effect and remain available for three months.
Additional Clarifications and Technical Updates
· Updated requirements for environmental and health impact information
· Modernized product category naming conventions for consumer and commercial reporting
Stakeholders may submit comments on the proposal until December 29, 2025. The exemptions are expected to reduce industry compliance costs by $786 million to $843 million, significantly easing obligations for small businesses.
