TSCA PFAS Reporting: 2026 Compliance Guide

02-07-2026

TSCA PFAS Reporting: 2026 Guide

TSCA PFAS Reporting is becoming one of the most important chemical compliance obligations for companies placing products, articles, chemicals, mixtures, or materials on the U.S. market.

Under TSCA Section 8(a)(7), EPA finalized reporting and recordkeeping requirements for PFAS. The rule requires certain manufacturers and importers, including companies that imported PFAS-containing articles, to report information to EPA for PFAS manufactured or imported in any year since January 1, 2011. EPA states that reportable information includes PFAS uses, production volumes, disposal, exposures, and hazards.

For companies, the challenge is not only understanding the regulation. The bigger challenge is finding reliable product, material, supplier, and historical import data across complex supply chains.

This guide explains the latest TSCA PFAS Reporting updates, who may need to report, what information companies should collect, what deadlines matter, how to manage supplier evidence, and how ComplyMarket product compliance software can help companies prepare.

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How ComplyMarket product compliance software can help

TSCA PFAS Reporting is not only a regulatory filing task. It is a supplier data, material compliance, traceability, and evidence management challenge.

ComplyMarket’s PFAS Compliance & Reporting Software is designed to help companies manage PFAS compliance through material risk assessment, supplier engagement, digital declarations, regulatory checks, and reporting support. ComplyMarket states that its platform helps companies simplify PFAS compliance, automate supplier reporting, assess material risk, and manage PFAS attestations.

For companies preparing for TSCA PFAS Reporting, ComplyMarket can help in several practical ways.

1. Supplier PFAS data collection

ComplyMarket can support structured supplier engagement, helping companies request and collect PFAS declarations, supplier attestations, material information, SDS files, and supporting documentation.

This helps reduce manual follow-up and improves the consistency of supplier responses.

2. Product and material traceability

Companies need to link PFAS information to products, components, suppliers, materials, sites, and reporting years. ComplyMarket helps organize this information in one compliance workflow so teams can understand where PFAS risk exists and which evidence supports each decision.

3. Material risk assessment

ComplyMarket describes material risk scoring and AI material risk assessment as part of its PFAS compliance capabilities.

This can help companies prioritize high-risk materials and focus supplier outreach where it matters most.

4. Digital declarations and evidence management

ComplyMarket provides a central hub to collect, manage, and audit supplier PFAS attestations.

For TSCA PFAS Reporting, this supports better recordkeeping, clearer documentation, and easier internal review.

5. Multi-regulation compliance coverage

PFAS compliance is not limited to one EPA rule. Companies may also face U.S. state PFAS requirements, customer requirements, restricted substance lists, and international product compliance obligations. ComplyMarket states that its platform supports automatic checks for PFAS, REACH, RoHS, TSCA, POPs, and more.

This allows companies to use PFAS data for broader compliance needs, not only TSCA reporting.

6. Reporting readiness before the EPA window opens

The updated reporting timeline gives companies more time, but it does not remove the need to prepare. ComplyMarket helps companies move from scattered supplier emails and spreadsheets to a structured, traceable PFAS compliance process.

What companies need to know

TSCA PFAS Reporting requires certain companies that manufactured or imported PFAS, including PFAS-containing articles, in any year since January 1, 2011, to report data to EPA.

The current reporting start date is January 31, 2027, or 60 days after the effective date of EPA’s forthcoming final rule on the substantive reporting requirements, whichever is earlier.

Companies should not wait for the reporting window to open. They should use the available time to:

Identify products, articles, mixtures, and materials that may contain PFAS
Review historical U.S. manufacturing and import activity from 2011 onward
Collect supplier PFAS declarations, SDS files, material declarations, and technical evidence
Map PFAS information to products, suppliers, sites, and years
Prepare internal reporting logic and recordkeeping files
Monitor EPA’s final rule updates before submission

Why TSCA PFAS Reporting matters

PFAS are widely discussed because of their persistence, potential exposure concerns, and increasing regulatory scrutiny. For companies, TSCA PFAS Reporting creates a practical supply chain data obligation.

A company may need to answer questions such as:

Did we manufacture or import PFAS at any point since January 1, 2011?
Did we import articles that contained PFAS?
Which products, components, coatings, textiles, formulations, or materials may be affected?
Which suppliers can provide evidence?
Do we have historical import and volume data?
What information is known or reasonably ascertainable?
What should we report, and what should we document internally?

EPA’s rule is not limited to current products only. It requires companies to look back at historical activity, which can make data collection difficult for discontinued products, legacy suppliers, old materials, and past import records.

Latest TSCA PFAS Reporting updates for 2026

EPA finalized the TSCA PFAS reporting rule in October 2023. In April 2026, EPA finalized a change to the start of the reporting period. The submission period will now begin on January 31, 2027, or 60 days following the effective date of a forthcoming final rule on the substantive requirements, whichever is earlier.

EPA also proposed changes to the scope of the TSCA PFAS reporting regulations in November 2025. EPA states that the proposed changes include exemptions and modifications intended to reduce unnecessary or duplicative reporting requirements. These proposed exemptions include PFAS in mixtures or products at concentrations of 0.1% or lower, imported articles, certain byproducts, impurities, research and development chemicals, and non-isolated intermediates.

The key point for companies is this: proposed exemptions are not final until EPA completes the final rulemaking process. Companies should continue preparing data and evidence until the final scope is confirmed.

Key TSCA PFAS Reporting dates

Topic	Current status
Final rule	EPA finalized TSCA Section 8(a)(7) PFAS reporting and recordkeeping requirements on October 11, 2023.
Historical lookback period	EPA states that the rule applies to PFAS manufactured or imported in any year since January 1, 2011.
Current reporting start	The reporting period begins on January 31, 2027, or 60 days after the effective date of EPA’s forthcoming final substantive rule, whichever is earlier.
Standard submission period	EPA states that when the submission period begins, manufacturers will have six months to provide their data.
Article importer / small manufacturer timing	Current eCFR text provides a twelve-month submission period for small manufacturers reporting exclusively as article importers.
Proposed scope changes	EPA proposed revisions in November 2025, including possible exemptions for imported articles and other categories, but these should not be treated as final yet.

Who may need to report?

TSCA PFAS Reporting may apply to companies that manufactured or imported PFAS for a commercial purpose during the rule’s lookback period. EPA’s reporting instructions state that reporting is required for manufacturers, including importers, of PFAS manufactured or imported for commercial purposes during the lookback period.

Potentially affected companies may include:

Company type	Why it may be affected
Chemical manufacturers	PFAS may have been manufactured directly or formed as part of chemical manufacturing activities.
Importers	Under TSCA, manufacture includes import, so import activity can trigger reporting obligations.
Article importers	Current rules include streamlined reporting options for importers of articles containing PFAS.
Finished goods brands	PFAS may be present in coatings, textiles, electronics, packaging, components, or supplier materials.
Distributors and private-label sellers	Historical import responsibility may need to be reviewed.
Procurement and supplier management teams	Supplier declarations and supporting evidence may be needed to determine reportability.
Compliance and legal teams	Internal decisions, data gaps, confidentiality claims, and evidence files need to be documented.

This is why TSCA PFAS Reporting should not be viewed only as a chemical manufacturer issue. It may also affect companies importing finished products, parts, components, or articles into the United States.

What counts as PFAS under the rule?

EPA defines PFAS for this reporting rule using a structural definition. EPA states that “PFAS” refers to chemical substances that meet the structural definition codified at 40 CFR 705.3.

This matters because companies cannot rely only on common PFAS names. PFAS may appear under:

CAS numbers
Trade names
Proprietary mixture names
Confidential chemical identities
Supplier-specific material descriptions
Fluoropolymer or fluorochemical terminology
Coating, treatment, membrane, or additive descriptions

For complex products, technical review may be needed to determine whether a substance meets EPA’s PFAS definition.

What information must be reported?

EPA states that reportable information includes PFAS uses, production volumes, disposal, exposures, and hazards.

The eCFR states that reporting must be submitted to the extent the information is known to or reasonably ascertainable by the submitter. If actual data is not known or reasonably ascertainable, reasonable estimates may be submitted.

Companies should prepare to collect and organize the following information:

Data category	Examples of information to collect
Company and site information	Legal entity, U.S. parent company, reporting site, technical contact, authorized official
PFAS identity	CAS number, chemical name, trade name, generic name, molecular identity, supplier-provided identity
Product and article mapping	Products, components, materials, mixtures, articles, coatings, and formulations that may contain PFAS
Use information	Industrial, commercial, or consumer use; product category; function of PFAS
Historical activity	Manufacturing, importing, processing, or article import activity from 2011 onward
Volume information	Production volume, import volume, article volume, or reasonable estimates
Concentration information	Known or estimated PFAS concentration in products, articles, materials, or mixtures
Supplier evidence	Supplier declarations, SDS, full material declarations, technical datasheets, test reports
Exposure information	Worker exposure, consumer exposure, commercial exposure, and relevant use conditions
Disposal and release information	Waste handling, disposal methods, byproducts, releases, recycling, incineration, or landfill information
Health and environmental information	Existing studies or information known to or reasonably ascertainable by the company

What does “known or reasonably ascertainable” mean?

The eCFR defines “known to or reasonably ascertainable by” as information in a person’s possession or control, plus information that a reasonable person in a similar situation might be expected to possess, control, or know.

For companies, this means a practical review should go beyond one internal spreadsheet. Relevant information may sit across several departments and systems.

Information source	Why it matters
Bills of materials	Helps identify components, parts, coatings, materials, and assemblies
Supplier declarations	Provides supplier-level evidence of PFAS presence, absence, or unknown status
SDS files	Supports chemical and mixture review
Full Material Declarations	Helps assess substance-level composition
Import records	Supports historical review of articles and products entering the U.S.
Purchase records	Helps identify suppliers, materials, and historical sourcing
Engineering specifications	May reveal PFAS-related performance requirements such as chemical resistance, oil resistance, or water resistance
Technical datasheets	May identify coatings, membranes, lubricants, seals, or additives
Test reports	Can support high-risk material investigation
Supplier correspondence	Documents due diligence and unresolved information gaps

A strong compliance process should document what was reviewed, who was contacted, what was received, what remains unknown, and why a conclusion was reached.

Important: Proposed exemptions are not final yet

EPA’s November 2025 proposal includes possible exemptions and modifications for several categories, including:

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

EPA describes these as proposed changes to the TSCA Section 8(a)(7) PFAS reporting regulations.

Companies should not assume that a proposed exemption already applies. Until EPA publishes the final revisions, compliance teams should continue preparing PFAS data, supplier evidence, and internal decision records.

A practical approach is to classify each product, material, or supplier record as:

Status	Meaning
Confirmed reportable	Evidence indicates PFAS activity that may need to be reported
Potentially reportable	PFAS risk exists, but more supplier or technical data is needed
Pending final rule	A proposed exemption may apply, but final EPA confirmation is needed
Not reportable based on evidence	Documentation supports a conclusion that reporting is not required
Unknown / data gap	Information is missing and additional due diligence is needed

Are imported articles covered?

Under the current rule, article importers are addressed in the reporting framework. The eCFR includes a streamlined reporting option for importers of articles containing PFAS, and it requires article importers to submit information to the extent they know or can reasonably ascertain it.

However, imported articles are also included in EPA’s November 2025 proposed exemptions.

This creates an important compliance point: article importers should continue preparing until EPA finalizes the scope. Even if an exemption becomes final, supplier PFAS data may still be needed for customer requests, U.S. state PFAS laws, retailer requirements, restricted substance lists, and international product compliance.

Are small manufacturers exempt?

EPA’s reporting instructions state that no small manufacturer exemptions are in effect for this data call. EPA notes that companies may be required to report under the PFAS data call even if they are not required to report under other TSCA requirements, such as Chemical Data Reporting, due to a small manufacturer exemption.

This means company size alone should not be used as the basis for ignoring TSCA PFAS Reporting. Applicability should be assessed based on activity, product scope, import status, PFAS presence, and EPA’s final rule requirements.

How companies should collect supplier PFAS data

Supplier engagement is one of the most important steps in TSCA PFAS Reporting preparation. Many companies will not have complete PFAS information internally, especially for complex products, imported articles, or historical materials.

A supplier request should be specific and evidence-based. Instead of asking only “Is this product compliant?”, companies should request information such as:

Supplier data request	Why it matters
PFAS presence or absence declaration	Helps determine whether PFAS may be present in a product, article, material, or mixture
Affected part numbers	Connects the declaration to the correct product scope
Chemical identity	Supports substance-level review and reporting
CAS number or generic identity	Helps address reportability and confidential identity issues
Concentration range	Supports reporting and risk prioritization
Function of PFAS	Explains why PFAS is used, such as coating, lubricant, membrane, additive, or surface treatment
Historical supply period	Helps assess whether the material was supplied during the lookback period
SDS or technical datasheet	Supports chemical and mixture review
Full Material Declaration	Provides more complete material-level evidence
Reformulation statement	Helps identify whether PFAS was removed or replaced over time
Authorized signature	Improves accountability and evidence quality

Supplier data should also be reviewed for quality. A generic declaration that does not mention specific products, materials, part numbers, or dates may not be strong enough for a historical reporting assessment.

Product and material categories that may need closer PFAS review

PFAS may be used for performance characteristics such as water resistance, oil resistance, stain resistance, grease resistance, chemical resistance, heat resistance, weather resistance, non-stick properties, or low friction.

The following categories should not be treated as automatically containing PFAS, but they may deserve closer review:

Product or material area	Why it may be relevant
Textiles, apparel, footwear, upholstery	PFAS may be used in water, oil, or stain-resistant finishes
Electronics and electrical equipment	PFAS may appear in insulation, cables, membranes, coatings, or processing applications
Automotive and industrial components	PFAS may be used in seals, gaskets, hoses, lubricants, coatings, and high-performance polymers
Packaging and food-contact materials	Some applications may involve grease-resistant or barrier properties
Cookware and kitchen products	Non-stick or heat-resistant surfaces may require review
Chemical mixtures and formulations	PFAS may be intentionally added or present in certain formulations
Medical and laboratory materials	Specialized tubing, membranes, filters, or chemical-resistant parts may need assessment
Construction products	Coatings, membranes, sealants, or treated surfaces may be relevant
Firefighting-related materials	Certain technical materials and foams may involve PFAS concerns

A risk-based screening process helps companies prioritize supplier outreach and evidence collection.

What if PFAS information is missing?

Information gaps are common, especially for older products, discontinued parts, legacy suppliers, or confidential chemical identities.

Companies should avoid undocumented assumptions. If information is missing, the company should document reasonable inquiry and explain the basis for any conclusion.

Situation	Recommended action
Supplier does not respond	Send follow-up requests and document contact dates, recipients, and unanswered questions
Supplier provides a vague declaration	Request product-specific, part-specific, and date-specific clarification
Supplier claims confidentiality	Ask whether a generic name, joint submission, or direct EPA submission pathway may be appropriate
Historical supplier no longer exists	Review legacy SDS files, purchase records, import records, specifications, and internal databases
Product was discontinued	Confirm whether it was manufactured or imported during the lookback period
Exact concentration is unknown	Use supplier information, technical assessment, reasonable estimates, or testing where appropriate
PFAS risk is high but evidence is weak	Consider targeted testing or expert chemical review

The goal is to show a clear and reasonable compliance process.

TSCA PFAS recordkeeping requirements

Recordkeeping is not optional. The eCFR states that each person subject to the reporting requirements must retain records documenting the information reported to EPA for 5 years beginning on the last day of the submission period.

A strong recordkeeping file should include:

Record type	Purpose
Product scope list	Shows which products, articles, materials, and mixtures were assessed
Supplier request log	Documents outreach and follow-up activity
Supplier declarations	Supports presence, absence, unknown, or restricted-information conclusions
SDS and technical documents	Supports chemical identity and formulation review
Full Material Declarations	Supports substance-level evidence
Import and production records	Supports historical activity and volume calculations
Risk assessment notes	Explains why certain materials were prioritized
Test reports	Supports conclusions for high-risk or uncertain materials
Internal decision log	Documents reportable, not reportable, pending, and unknown items
Final reporting file	Supports EPA submission and future audits

Practical TSCA PFAS Reporting readiness workflow

Step	Action	Business output
1	Define the reporting scope	List U.S. entities, sites, product lines, imported articles, chemicals, and mixtures
2	Map historical activity	Identify manufacturing and import activity from 2011 onward
3	Prioritize PFAS risk areas	Focus on high-risk materials, coatings, treatments, and formulations
4	Launch supplier data requests	Collect declarations, SDS files, FMDs, technical datasheets, and supporting evidence
5	Review chemical identity	Determine whether substances meet EPA’s PFAS definition
6	Link data to products	Connect PFAS evidence to product numbers, suppliers, sites, years, and volumes
7	Assess data gaps	Identify unknown, missing, confidential, or not reasonably ascertainable information
8	Prepare reporting logic	Classify items as reportable, potentially reportable, not reportable, or pending final rule
9	Build evidence files	Organize documentation for reporting and recordkeeping
10	Monitor EPA updates	Update the assessment when EPA finalizes substantive rule revisions

Common mistakes to avoid

Mistake	Why it creates risk
Waiting until the reporting window opens	Supplier data collection can take months, especially for complex supply chains
Assuming imported articles are already exempt	Imported articles are part of a proposed exemption, but proposed changes are not final yet
Reviewing only current products	The rule has a historical lookback period going back to January 1, 2011
Asking suppliers vague questions	Generic compliance confirmations may not support TSCA PFAS reporting decisions
Ignoring discontinued products	Legacy products may still fall within the lookback period
Keeping evidence in scattered emails	Reporting and recordkeeping require traceable documentation
Treating “unknown” as enough	Companies should document reasonable inquiry and data gap management
Forgetting volume and use data	Reporting may require more than PFAS presence or absence information

FAQ: TSCA PFAS Reporting

What is TSCA PFAS Reporting?

TSCA PFAS Reporting is EPA’s reporting and recordkeeping requirement under TSCA Section 8(a)(7). It requires certain manufacturers and importers of PFAS, including PFAS-containing articles, to electronically report information to EPA.

Who must report under TSCA PFAS?

Companies that manufactured or imported PFAS for commercial purposes during the lookback period may need to report. This can include chemical manufacturers, importers, and article importers, depending on the final scope and available evidence.

What is the TSCA PFAS Reporting deadline?

The reporting period is currently set to begin on January 31, 2027, or 60 days after the effective date of EPA’s forthcoming final substantive rule, whichever is earlier.

Do article importers need to prepare?

Yes. Current rules include article importer reporting provisions and streamlined reporting options. EPA has proposed an imported article exemption, but companies should not treat that proposal as final until EPA completes the final rulemaking.

Is there a small manufacturer exemption?

EPA’s reporting instructions state that no small manufacturer exemptions are in effect for this PFAS data call.

What data should companies collect?

Companies should collect supplier declarations, SDS files, full material declarations, product and article mapping, PFAS identity information, use information, volume data, exposure information, disposal information, and supporting evidence.

How long should records be kept?

Records documenting information reported to EPA must be retained for 5 years beginning on the last day of the submission period.

Should companies wait for the final EPA revisions before preparing?

No. Companies should monitor the final rule, but they should begin preparing product mapping, supplier evidence, and internal records now. Waiting may create unnecessary pressure when the reporting window opens.