EPA Again Delays PFAS Reporting Rule

On May 13, 2025, EPA issued an interim final rule delaying implementation of the PFAS reporting requirements under the Toxic Substances Control Act (TSCA), citing technical difficulties.

The submission period is now scheduled to begin on April 13, 2026, instead of July 11, 2025.  It will close on October 13, 2026, with an alternate deadline of April 13, 2027, for small manufacturers reporting exclusively as article importers.

The rule states that the delay will “ensure that the project team has adequate time to complete development and testing” of the Central Data Exchange (CDX) reporting tool.  EPA also notes that it will give the agency time to consider reopening elements of the PFAS reporting rule in light of Executive Order 14192: Unleashing Prosperity Through Deregulation, issued by the Trump administration.

This is the second delay to the rule’s implementation.  In September 2024, EPA postponed the original November 2024 start date, also citing incomplete software development.  At the time, the agency attributed the delay to reduced funding.

Congress has since appropriated additional funds for TSCA’s information technology infrastructure in the FY2025 Continuing Resolution, passed just two days before EPA issued the May 13 rule.

Once implemented, the PFAS reporting rule will require all persons who manufactured or imported PFAS for commercial purposes from 2011–2022 to report information to EPA.  More on its requirements can be found here.