Under the Toxic Substances Control Act, companies that have manufactured or imported per- and polyfluoroalkyl substances – better known as PFAS – are required to report on those chemicals going back more than a decade.

The original reporting period was scheduled to begin in November 2024 and was delayed until April 2026 – but on April 9, the EPA finalized a further delay, moving the start of the reporting period to a date yet to be determined.

  • The new reporting period will open 60 days following the effective date of a forthcoming, updated final rule, or by January 31, 2027, whichever is earlier.
  • The reporting window will be six months for most entities.


This latest extension allows the EPA more time to ready the reporting software and to review over 8,000 public comments received on the November 2025 proposed updates, which include exemptions and modifications to reduce duplicative reporting requirements for manufacturers. A final rule is expected to be published later this year.

ICYMI: EPA Proposes Changes To PFAS Reporting Requirements

Reporting is required for any company that has manufactured or imported PFAS for commercial purposes at any time since January 1, 2011. Companies that acquired PFAS domestically and used it in their operations would not be required to report under the rule.

  • The EPA has published a list of substances online that are defined as PFAS.
  • The rule applies to imported articles containing PFAS. If companies imported articles and can reasonably ascertain that those articles contain PFAS, they must report.
  • There is no exception for small businesses or small amounts of PFAS, although small businesses will have more time to report and a later deadline.


Noncompliance includes failing to report, failing to maintain records or submitting inaccurate information. Each violation of the reporting requirements can trigger civil fines of approximately $50,000 per day.

Regulated entities should use this extra time to identify PFAS in their supply chains and prepare necessary documentation. 

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