EPA Proposes Changes to PFAS Reporting Rules to Reduce Regulatory Burden

On November 10, 2025, the U.S. Environmental Protection Agency (EPA) proposed revisions to the perfluoroalkyl and polyfluoroalkyl substances (PFAS) reporting requirements under the Toxic Substances Control Act (TSCA). These changes aim to make reporting more practical and implementable while reducing unnecessary or duplicative burdens on businesses, particularly small manufacturers and importers.

Background: One-Time PFAS Reporting Rule Finalized in 2023

In October 2023, EPA finalized a one-time PFAS reporting rule under TSCA section 8(a)(7). This rule required manufacturers (including importers) to report data on PFAS use, exposure, and health effects for any year between 2011 and 2022. However, the rule was criticized for imposing nearly $1 billion in compliance costs without clear implementation standards or demonstrated environmental benefits.

Key Proposed Exemptions

The new proposal seeks to maintain essential reporting requirements while exempting activities for which manufacturers are least likely to have information or be able to make reasonable determinations. Key proposed exemptions include:

• PFAS in mixtures or products at concentrations of 0.1% or lower
• Imported articles
• Certain byproducts and impurities
• Research and development chemicals
• Non-isolated intermediates

EPA also plans to make technical corrections to clarify reporting fields and adjust the data submission period.

The agency will accept public comments for 45 days following publication of the proposal in the Federal Register. Comments should be submitted to docket EPA-HQ-OPPT-2020-0549 at https://www.regulations.gov.