US EPA Delays TSCA PFAS Reporting Deadline for the Third Time

In a move that brings relief yet requires continued vigilance for businesses, the U.S. Environmental Protection Agency (EPA) has officially announced the third delay of the reporting deadline for per- and polyfluoroalkyl substances (PFAS) under Section 8(a)(7) of the Toxic Substances Control Act (TSCA). The final rule, signed by EPA Administrator Lee M. Zeldin on April 8, 2026, and published in the Federal Register on April 13, 2026, adjusts the start date of the PFAS reporting period, providing additional preparation time for affected manufacturers and importers.

This latest delay marks the third extension since the EPA initially finalized the PFAS reporting requirements on October 11, 2023. At that time, the agency issued the final rule 40 CFR 705, outlining mandatory reporting and record keeping obligations for PFAS. However, due to delays in the development of the electronic reporting system (CDX) and the need to review public comments, the EPA first pushed back the deadline on September 5, 2024—moving the original deadline from November 12, 2024, to July 11, 2025—followed by a second extension on May 13, 2025, which further delayed the deadline to April 13, 2026.

According to the new final rule, the PFAS reporting period will now begin on January 31, 2027, or 60 days after the effective date of the upcoming final rule on the substantive requirements of the PFAS reporting rule—whichever comes first. Importantly, the EPA has not adjusted the existing submission duration: standard reporters will still have a 6-month reporting window, while small article importers (exclusive article importers) will retain a 12-month period to complete their submissions.

The reporting requirements under TSCA Section 8(a)(7) remain unchanged in scope. Any entity that manufactured (including imported) PFAS or PFAS-containing articles for commercial purposes between 2011 and 2022 is obligated to report detailed information to the EPA. This includes data on chemical identity, uses, production and processing volumes, byproducts, environmental and health impacts, worker exposure, and disposal practices.

EPA Administrator Lee M. Zeldin noted that the delay is intended to allow the agency to thoroughly review thousands of public comments received on previous proposals, finalize the CDX electronic reporting tool, and update technical guidance documents. For businesses, this extension provides a critical window to organize historical data, verify compliance with reporting requirements, and address any gaps in their PFAS documentation.

Key Takeaways for Affected Entities:

1. The reporting period start date is delayed to January 31, 2027, or 60 days after the upcoming substantive rule takes effect (whichever is earlier).
2. Submission durations remain unchanged: 6 months for standard manufacturers/importers, 12 months for small article importers (exclusive article importers).
3. Reporting obligations still apply to all entities that manufactured or imported PFAS between 2011 and 2022.
4. Businesses should use the extra time to review their PFAS supply chains, compile required data, and prepare for electronic submission via the CDX platform.

As PFAS regulation continues to evolve globally, staying updated on EPA’s requirements is crucial for avoiding compliance risks.