On November 10, 2025, the U.S. Environmental Protection Agency (EPA) released a proposal to significantly narrow the scope of its per- and polyfluoroalkyl substances (PFAS) reporting rule under Section 8(a)(7) of the Toxic Substances Control Act (TSCA), just two years after finalizing the original rule in October 2023. The 2023 rule requires manufacturers, including importers, of PFAS and PFAS-containing products to submit extensive one-time reports to EPA covering any year of manufacture or import between January 1, 2011 and December 31, 2022.

The EPA has proposed significant changes to its 2023 PFAS reporting rule, marking a major shift from what had been one of the most expansive information-collection requirements ever imposed on manufacturers and importers. The EPA now claims that the rule created substantial and often impractical burdens, particularly for small businesses and article importers attempting to reconstruct decade-old supply-chain information with limited records.

In its new proposal, the EPA seeks to narrow the rule’s scope by exempting article importers entirely, as well as PFAS present in mixtures or products at concentrations of 0.1 percent or less. The agency also proposes exemptions for byproducts, impurities, non-isolated intermediates, and certain research and development substances. These changes would remove a large portion of downstream entities from the rule and will allegedly reduce total industry compliance costs by more than $750 million. The EPA describes the revised approach as a practical recalibration that focuses on information most relevant to evaluating PFAS uses and exposures while avoiding what it now characterizes as disproportionate burdens.

Some environmental groups warn that excluding articles and low-concentration PFAS could leave substantial gaps in the national PFAS picture, given the prevalence of PFAS in global supply chains and the toxicity of certain compounds at very low levels. They argue that the exemptions risk obscuring potential PFAS sources at a time when regulators and communities are seeking more visibility into how these chemicals enter commerce.

EPA also proposes altering the timing of compliance by delaying and shortening the reporting window, citing delays in developing its electronic reporting system. Once published in the Federal Register, the proposal will be open for a 45-day comment period, during which regulated entities will have the opportunity to weigh in on whether the narrowed rule appropriately balances EPA’s information needs with practical implementation concerns. Businesses that manufacture PFAS or import PFAS-containing products should consider evaluating how these proposed changes may affect their reporting obligations and whether to submit comments.