U.S. Toxic Substances Control Act (TSCA)
September 23, 2025 | Written by GreenSoft Technology, Inc.
Plan to Implement Exemptions, Modifications to Scope of TSCA 8(A)(7) PFAS Rule Confirmed
EPA plans to issue a notice of proposed rulemaking (NPRM) in December 2025
In our May 29, 2025 blog post, we reported on the EPA’s April 28, 2025 press release announcing its intent to “implement section 8(a)7 to smartly collect necessary information, as Congress envisioned and consistent with TSCA, without overburdening small businesses and article importers."
This was a direct indication from the EPA that they are considering reducing or eliminating the reporting obligations for small producers, and more importantly, for article importers.
On September 4, the US Office of Management and Budget (OMB) published the Trump Administration’s Spring 2025 Unified Agenda. According to the Unified Agenda, EPA has confirmed their plans to propose the incorporation of certain exemptions and other modifications to the scope of the reporting rule. EPA intends to issue a notice of proposed rulemaking (NPRM) in December 2025 and a final rule in June 2026. Details on this action can be found here.
Background on the TSCA Section 8(a)(7) reporting and recordkeeping requirements for PFAS
Under the current TSCA Section 8(a)(7) reporting and recordkeeping requirements, any company that has manufactured or imported PFAS within the United States, or has imported PFAS-containing articles in any year between January 1, 2011 and December 31, 2022 are required to electronically report information regarding PFAS uses, production volumes, disposal, exposures, and hazards to the EPA.
The reporting period was originally scheduled to begin in November of 2024 before being delayed to July 2025. On May 13, 2025, EPA announced yet another delay the start of the reporting period by nine additional months to April 13, 2026. Most reporters will be required to complete all reporting by October 13, 2026. Small businesses reporting data solely on importing PFAS contained in articles will have until April 13, 2027 to submit reports.
More information from the EPA on the rule can be found online. Additionally, GreenSoft Technology maintains a PFAS Resource Center with information on PFAS regulations and proposals around the globe, which can be found here.
GreenSoft helps identify PFAS chemicals in your supply chain for TSCA compliance
GreenSoft Technology’s PFAS Data Services solution provides affected companies with the chemical data from their supply chain that is needed to comply with the TSCA Section 8(a)(7) rule.
Our data collection team will contact your suppliers directly to obtain data on the PFAS chemicals contained in your products and components as per the PFAS definition noted in TSCA Section 8(a)(7).
With our Turnkey Service, we can generate the necessary compliance reports for you. Or you can use our GreenData Manager software to manage your company’s substance database and easily generate reports for this and other environmental regulations. Contact us to learn more.
