The EPA has released a proposal to amend its PFAS reporting requirements under TSCA Section 8(a)(7). The agency aims to make the regulation more practical for manufacturers and importers while still collecting information it considers essential. The proposal follows widespread concerns about the 2023 final rule, which required PFAS manufacturers and importers to submit detailed data covering activity between 2011 and 2022. That rule drew criticism for high costs, unclear implementation, and challenges within the reporting system. EPA announced the new proposal in a November 10, 2025 press release.
Background on the 2023 TSCA PFAS Reporting Rule
The original 2023 TSCA Section 8(a)(7) final rule required manufacturers and importers to report chemical identity, use categories, production volumes, by-products, exposures, disposal practices, and any environmental or health effect data associated with PFAS. The EPA designed it as a one-time, comprehensive data-collection effort to fill gaps in PFAS lifecycle information.
Industry groups argued that the rule imposed a near–US $1 billion compliance burden and raised concerns about unclear data-use frameworks and reporting-system challenges.
Key Changes in EPA’s Proposed PFAS Reporting Revisions
The new pre-publication proposal introduces several exemptions that significantly narrow the reporting scope. The EPA proposes a 0.1% by-weight threshold for PFAS in mixtures or products, exempting materials below that level. The proposal also exempts imported articles containing PFAS, PFAS present as impurities, certain by-products, non-isolated intermediates, and small-quantity research-and-development substances.
External legal analyses, such as a review from Arnold & Porter, estimate that these changes could reduce compliance costs by US $786 million to US $843 million. The EPA also seeks to refine definitions, clarify reporting fields, and adjust the submission window.
Impact of the Proposal on PFAS Testing and Analytical Workflows
For laboratories and analytical scientists, the proposal may reshape where PFAS characterization efforts are prioritized. A 0.1% threshold shifts regulatory focus toward higher-concentration applications, affecting the kinds of materials industry partners may ask labs to evaluate. Exemptions for imported articles reduce the need to investigate PFAS in finished goods that typically contain trace-level residues requiring complex analysis.
Exemptions for impurities and certain by-products may reduce upstream analytical burdens. Labs that support manufacturers with PFAS screening during synthesis or process evaluation may see narrower reporting-driven demand, while attention may increase on PFAS substances that remain fully within scope.
Timeline and What Analytical Teams Should Monitor
The EPA will accept comments for 45 days following publication of the proposal in the Federal Register. Until a revised rule is finalized, the 2023 rule remains active. Manufacturers and importers must continue using current requirements to determine their obligations.
Regulatory discussions are expected around whether the EPA should adopt a discrete PFAS list instead of the existing structural definition, whether specific exemptions should be expanded or removed, and whether production-volume thresholds should be added.
Summary of EPA’s Proposed PFAS Reporting Adjustments
EPA’s proposed revisions to PFAS reporting under TSCA Section 8(a)(7) aim to target essential data, reduce unnecessary burden, and clarify reporting expectations. The proposed exemptions and technical adjustments will shape which PFAS materials require documentation and how industry prioritizes analytical testing. Analytical scientists should track the proposal’s progression, as the final rule may influence PFAS method development, testing workflows, and data-collection strategies.