Key Reporting Obligations and Deadlines

All manufacturers, including importers, must report data on PFAS activities between January 1, 2011 and the applicable reporting deadline.

Submission deadlines:

• January 11, 2026 – for standard manufacturers and importers.
• July 11, 2026 – for small manufacturers (as defined in 40 CFR 704.3) importing PFAS solely as articles.

Records must be retained for five years following submission.

⚙️ Reporting Requirements under TSCA Section 8(a)(7)

Each company must disclose all information known or reasonably ascertainable, including:

• PFAS uses and production volumes
• By‑products and disposal routes
• Environmental and human exposure data
• Known or suspected health effects

EPA’s CDX portal offers three forms: the Standard Form, Simplified Article Importer Form, and Simplified R&D Form.

🛡️ The “Known to or Reasonably Ascertainable” Standard

This criterion requires companies to report information that a reasonable person in a similar position should know or control.

Factors include:

• Company size and available resources
• Supplier relationships and communication frequency
• Supplier responsiveness and data availability

New supplier surveys are not mandatory if existing records suffice.

However, all data searches and correspondence must be documented for five years.

📜 Recommended Compliance Workflow

1- Record all U.S. sales volumes from 2011–2022.
2- Verify part numbers and bills of materials for those products.
3- Check whether PFAS conformity statements have been received from suppliers.

• ✅ If yes → report directly through CDX.
• ❌ If no → conduct a material risk assessment.

4- Assess PFAS likelihood based on material families.
5- If risk is medium/high → request PFAS confirmation from suppliers.
6- If suppliers fail to respond → escalate to legal department and retain correspondence for five years.

This structured sequence supports due diligence under EPA’s KRA expectations.

🧪 Mandatory Data Elements

For every PFAS and year, submit to EPA:

• Generic name (if confidential) and CAS/LVE identifier
• Trade name or molecular structure (attachments as needed)
• Industrial process codes (e.g., reactant use, formulation integration, article incorporation)
• Sector codes (IS1–IS29) per EPA’s official list
• Function and product categories (industrial and consumer)
• Concentration ranges in finished products
• Import volumes and measurement units

Providing complete and verified information reduces rejection risk during EPA review.

🧭 Sectors Where PFAS Are Commonly Used

PFAS compounds appear throughout industrial and consumer supply chains due to their exceptional chemical resistance and durability:

• Cookware and Packaging: Non‑stick coatings and grease‑resistant layers.
• Textiles and Carpets: Water‑ and stain‑resistant treatments.
• Waterproof Clothing: Repellency and breathability finishes.
• Firefighting Foams: AFFF solutions in aviation and industrial response.
• Electronics: Surfactants, coolants, and photoresist materials.
• Aerospace and Automotive: Lubricants, sealants, and hydraulic fluids.
• Metal Processing: Wetting agents and mist suppressants.
• Paints and Sealants: Chemical‑ and weather‑resistance additives.
• Cleaning Agents: Specialized removers for oil and grease.

✅ Best Practices for Compliance

• Establish a central PFAS inventory covering U.S. sales since 2011.
• Maintain robust supplier communication and testing records.
• Verify PFAS‑free claims with lab data or conformity declarations.
• Implement a document management system to store EPA submissions for five years.
• Educate procurement and compliance staff on TSCA reporting and KRA expectations.

🤝 How ComplyMarket Can Help

Adhering to the EPA’s PFAS reporting requirements under TSCA Section 8(a)(7) demands coordinated planning, supplier collaboration, and precise documentation.

ComplyMarket supports manufacturers and importers by:

• Interpreting the TSCA Section 8(a)(7) rule and EPA implementation guidance,
• Organizing data collection and chemical testing to verify PFAS presence,
• Preparing EPA submission files and recordkeeping templates, and
• Guiding companies through supplier engagement and due‑diligence processes.

With expert assistance, businesses can achieve complete PFAS reporting compliance by 2026 and sustain long‑term regulatory assurance in the U.S. market.