PFAS Reporting Rule Update: OMB Clears Path for EPA to Ease Requirements

EPA is a step closer to easing PFAS reporting requirements for manufacturers and importers after the Office of Management and Budget (OMB) completed its review of a proposed rule on October 24, 2025, that is likely to introduce exemptions.

Background: The Current PFAS Reporting Rule

The Toxic Substances Control Act (TSCA) section 8(a)(7) PFAS reporting rule, finalized in 2023, requires entities that manufactured or imported PFAS in any year from 2011–2022 to report extensive data to EPA.  Unlike other TSCA reporting obligations, the rule does not exempt articles, de minimis quantities, byproducts, or impurities—drawing criticism from industry groups, who argue that its broad scope is both unnecessary and overly burdensome.

As discussed in a previous post, the rule’s original 2024 reporting deadline has already been delayed twice to 2026 because of technical difficulties.  However, in the most recent postponement, EPA signaled that it was considering reopening elements of the rule to align with the Trump administration’s deregulatory agenda.  On August 29, 2025, it submitted the proposal to OMB for regulatory review.

What’s Next

According to the Spring 2025 Unified Agenda, the rulemaking will incorporate “certain exemptions and other modifications to the scope of the reporting rule.”  The proposed rule is expected in December 2025, and EPA plans to finalize the rulemaking in June 2026.

More on the PFAS reporting rule’s requirements can be found in a previous post.