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 and outlines practical steps to prepare for the upcoming submission window (April 13–October 13, 2026).

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

Submission Window and Deadlines

EPA established a reporting “submission window” to give facilities time to prepare and submit data. For most parties subject to the rule, they have from April 13, 2026 to October 13, 2026 to submit their report.

For small manufacturers that only import PFAS-containing articles, EPA has extended the deadline to April 13, 2027.

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 submissions
  • Reports must be submitted through EPA’s CDX website. Facility representatives should create an account if they do not already have one
• Watch for final rule updates
• 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.