Your Guide to PFAS Reporting Requirements, Part 3: What Are the Requirements?

by | May 15, 2025

In Part 1 and Part 2 of this blog series, we discussed what PFAS are and EPA actions to regulate these chemicals, respectively. Here, we will detail the current PFAS reporting requirements. This blog series covers our recently published PFAS reporting guide, which is available to download in full here.

 

Reporting Required by the EPCRA

PFAS were first required to be reported on the Toxics Release Inventory (TRI) beginning on January 1, 2020, under the Emergency Planning and Community Right-to-Know Act (EPCRA). The EPCRA requires any business that manufactures, processes, or otherwise uses PFAS chemicals above 100 pounds to report that on the TRI report, which is due July 1 each year. For reporting year 2024, 196 PFAS are reportable.

 

Reporting Required by the TSCA

On September 28, 2023, the United States Environmental Protection Agency (EPA) finalized a rule regulating reporting and recordkeeping requirements for PFAS as an amendment to the Toxic Substances Control Act [TSCA section 8(a)(7)]. It is important to understand that this rule also requires PFAS to be reported, but it is separate from the EPCRA PFAS reporting on the TRI.

With the TSCA rule, the EPA aims to understand just how extensive the use of PFAS has been in the past, where they are used today, and what they are used for. The widespread use of these chemicals means that nearly any company in business since 2011 will have to comply.

The EPA’s final rule under the TSCA requires manufacturers and importers of PFAS and PFAS-containing articles in any year since 2011 to report information to the EPA on PFAS uses, production volumes, disposal, exposures, and hazards. In short, the TSCA requires any organization that may have had PFAS-containing substances mingled in with its supply chain to perform a one-time audit for EPA data collection purposes.

 

The State of PFAS Regulations Overall

This update to the TSCA rule is one of many recent regulations at the federal and state levels designed to address the dangers of these “forever chemicals” and to encourage organizations that use such substances to consider using alternative materials instead.

However, that is easier said than done. Some of these chemicals cannot be easily or cost-effectively replaced or removed from industrial applications, and if it seems as though PFAS are everywhere, that’s because they are. PFAS can be found in your water, clothes, shoes, and fast food, to name just a few.

Complicating the situation further, there are no laws in the United States governing the use of these substances (except the few that are restricted) or requiring manufacturers to be transparent with consumers concerning the use of PFAS chemicals. Although some of the “more hazardous” ones have been banned, thousands more still continue to be used.

For help understanding the current PFAS-related regulations that apply to your facility, contact Walden’s expert consultants at 516-559-6976. For further reading, visit our previous blogs on PFAS or download our guide.

water sample, PFAS, PFAS reporting, PFAS regulations, environmental consulting

To learn more about PFAS reporting requirements, contact Walden’s knowledgeable environmental consultants at 516-559-6976.