EPA Extends Date for Required PFAS Reporting
This week the Environmental Protection Agency ("EPA") announced a final rule that will delay the reporting period for goods made with per- and polyfluoroalkyl substances ("PFAS") until January 2027.
On April 13, 2026, the EPA issued a final rule to extend the timeline for the PFAS Reporting Rule, which concerns reporting obligations that are applicable to manufacturers and importers of goods containing PFAS. Under this final rule, the six-month reporting period will now begin either on January 31, 2027, or 60 days following the effective date of a forthcoming final rule on the substantive requirements of the PFAS Reporting Rule, whichever is earlier. The submission period was previously scheduled to begin on April 13, 2026. This revision of the submission deadline is one of multiple extensions that have occurred under both the Biden and the Trump administrations. In this final rule, the EPA does not address the current duration of the submission period; thus, the six-month submission period, with an additional six months for small manufacturers reporting only the import of articles, will remain.
The reporting requirement traces back to the 2020 National Defense Authorization Act, which directed the EPA to collect information from chemical manufacturers and importers regarding PFAS substances that they made or imported in any year between January 1, 2011, and December 31, 2022. In response, the Biden administration finalized the PFAS Reporting Rule, Toxic Substances Control Act section 8(a)(7). That final rule requires detailed reporting on the uses, production volumes, byproducts, exposures, disposal, and environmental and health effects of PFAS.
The Trump administration proposed revising the rule in November 2025 to incorporate exemptions and modifications as a way of reducing unnecessary reporting requirements. The proposed rule was drafted in response to opposition from manufacturers and importers in the industry. A final rule has not yet been issued.
The EPA has indicated that additional changes will be forthcoming and will include substantive revisions to the PFAS Reporting Rule, including the amount of information companies are required to report. The revised submission period will provide some relief for affected companies, but regulatory uncertainty remains.
