PFAS Reporting Update: What You Need to Know for 2026

The environmental compliance landscape for per- and polyfluoroalkyl substances (PFAS) continues to evolve. After the Environmental Protection Agency (EPA) finalized its PFAS reporting rule under TSCA Section 8(a)(7) in 2023, regulated parties have been working to understand and comply with the data collection requirements. Recent updates from EPA make it important for facilities to revisit their PFAS compliance plans.

This blog provides an updated summary of PFAS reporting requirements, recent changes to the reporting timeline, and practical steps businesses can take to prepare.

What the TSCA PFAS Reporting Rule Requires

In October 2023, the EPA finalized a recordkeeping rule which requires manufacturers and importers of PFAS to report information about PFAS production or importation from 2011–2022. Reportable information includes:

• Chemical identity and CAS numbers
• Amounts manufactured/imported
• Use categories
• Byproducts and impurities
• Exposure and disposal information, where known

Unlike annual reporting requirements (such as Toxics Release Inventory (TRI) reporting), this is a one-time historical reporting event designed to help EPA understand the presence and uses of PFAS.

Proposed Exemptions

In November 2025, EPA proposed some changes intended to make the final rule more practical and less burdensome for small businesses and importers. Proposed revisions include reporting exemptions for:

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

**Update: New Submission Window and Deadlines

The PFAS reporting timeline has changed from the previously established April 13, 2026 start date.

In April 2026 (after this blog’s initial publication date), EPA finalized another extension of the reporting timeline while the agency completes substantive revisions to the TSCA Section 8(a)(7) PFAS reporting rule. Under the revised schedule, the reporting period will begin 60 days after the effective date of EPA’s forthcoming final revisions to the rule, or January 31, 2027, whichever occurs first.

Once the reporting period begins, covered manufacturers and importers will generally have six months to submit the required information.

What You Should Do Now

To prepare for the upcoming submission deadline, facilities should:

• Determine applicability
  • Perform an internal evaluation of PFAS and PFAS-containing articles
• Assemble historical data on PFAS manufacturing, import volumes, and uses from 2011–2022
• Prepare for potential reporting
  • Reports must be submitted through EPA’s CDX website. Facility representatives should create an account if they do not already have one
• Monitor EPA’s final rule revisions
• Document
  • Even if your facility is not subject to PFAS reporting, it is always a good idea to document your findings and applicability status for future compliance clarity

How Walden Can Help

Walden is experienced in PFAS reporting and regulatory compliance. We can help you determine your reporting applicability, collect data, prepare your submission report, and more. Call us today at 860-846-4069 or download Walden’s guide to PFAS reporting requirements for additional information.