News Brief
Recently, the United States Environmental Protection Agency (EPA) issued a proposed rule to amend the PFAS Reporting and Recordkeeping Rule, aiming to improve its practical applicability and alleviate the compliance burden on businesses.
Background
In October 2023, the EPA, under Section 8(a)(7) of the Toxic Substances Control Act (TSCA), proposed mandatory reporting and recordkeeping requirements for PFAS.
This rule requires that any company that manufactured or imported PFAS or related products in any year between 2011 and 2022 is required to submit detailed information to the EPA, including data on manufacturing, use, exposure, and environmental impact. The rule has a broad scope, with no standard exemptions, requiring reporting on PFAS in byproducts, impurities, and articles.
However, the rule has been identified by the United States Government as a case of regulatory overreach. It has imposed a nearly $1 billion compliance burden on the industry while falling short of achieving the anticipated environmental benefits due to the lack of a clear data application framework and feasible implementation standards.
To address these issues, the EPA has proposed this amendment, which seeks to fundamentally reverse the situation. The new rule aims to lower overall industry compliance costs and provide greater regulatory certainty by streamlining reporting requirements and clarifying implementation details.
At the same time, this initiative will allow the EPA to focus on collecting PFAS data that is most valuable to achieving its environmental protection goals, thereby enhancing both regulatory efficiency and environmental protection.
Key Updates: Major Exemptions
The introduction of several key exemptions, including:
PFAS manufactured (including imported) in mixtures or products at concentrations 0.1% or lower;
Imported articles;
Certain byproducts;
Impurities;
Research and development chemicals; and
Non-isolated intermediates.
Key Updates: Adjustment to the Reporting Timeline
The EPA proposes that PFAS reporting is proposed to commence on the 60th day after the Final Rule’s effective date and will last for three months.
Important Reminder from REACH24H Consulting Group
The public comment period for the Proposed Rule will close on December 29, 2025, as announced by the EPA. Relevant companies may provide feedback on the proposed rule to the EPA before this deadline.
If the rule is finalized, the newly introduced exemption provisions will effectively reduce the reporting burden on companies, particularly alleviating compliance pressure for product types where PFAS data is difficult to obtain. This reflects the EPA’s increased focus on practical applicability in regulatory design.
Additionally, the reporting period originally scheduled to begin on April 13, 2026, will be adjusted accordingly.
REACH24H Consulting Group advises companies to closely monitor subsequent developments, proactively assess their PFAS usage, and establish systematic data collection and reporting mechanisms to mitigate compliance risks arising from information gaps or submission delays.
REACH24H will continue to track regulatory developments related to PFAS, assist companies in accurately understanding compliance requirements, and ensure the efficient fulfillment of reporting obligations. Furthermore, to control PFAS risks at the source, we also offer support for PFAS-Free Certification and the application of hazard assessment tools. These services help companies identify safer chemicals and promote the development of fluorine-free alternatives, thereby systematically enhancing compliance standardization and risk management capabilities.
For more information and inquiries, please feel free to contact us at customer@reach24h.com.
