Table of Contents
- What is TSCA Section 8(a)(7)?
- Who may need to report under TSCA Section 8(a)(7)?
- What is the current TSCA PFAS reporting deadline?
- What changed in the TSCA PFAS reporting requirements?
- What information may need to be reported?
- Chemical identity
- Manufacturing and import information
- Uses
- Byproducts and disposal
- Exposure information
- Health and environmental information
- How should product manufacturers identify PFAS for TSCA reporting?
- How should companies handle historical PFAS data?
- What if PFAS information is missing?
- How should supplier information support TSCA reporting?
- How should companies prepare while EPA revises the rule?
- 1. Determine potential reporting scope
- 2. Identify relevant PFAS
- 3. Build the reporting population
- 4. Map the required information
- 5. Resolve data gaps
- 6. Validate the data
- 7. Preserve evidence
- 8. Recheck the final rule
- TSCA PFAS reporting vs product PFAS compliance
- TSCA Section 8(a)(7)
- Product PFAS compliance
- Common TSCA PFAS reporting mistakes
- Assuming PFAS in a purchased component automatically creates a reporting obligation
- Using an old reporting deadline
- Treating proposed exemptions as final
- Treating supplier declarations as the final TSCA determination
- Mixing TSCA reporting with product restrictions
- Failing to preserve historical evidence
- How does TSCA Section 8(a)(7) fit into global PFAS compliance?
- TSCA Section 8(a)(7) preparation checklist
TSCA Section 8(a)(7) establishes reporting and recordkeeping requirements for certain entities that manufacture or import per- and polyfluoroalkyl substances (PFAS) in the United States. The requirements cover information such as chemical identity, production and import volumes, uses, disposal, exposures, byproducts and available health and environmental information.
For product manufacturers, discrete manufacturers and importers, the first question is whether the company's own activities fall within the TSCA reporting scope. The presence of PFAS in a purchased component or finished product does not, by itself, establish a reporting obligation.
Current status: EPA is revising the Section 8(a)(7) PFAS reporting requirements. In April 2026, EPA finalized a change that ties the start of the reporting period to 60 days after the effective date of the forthcoming rule revision. EPA expects to issue the revised rule in 2026.
What is TSCA Section 8(a)(7)?
Section 8(a)(7) of the Toxic Substances Control Act requires certain manufacturers and importers of PFAS to report information to the U.S. Environmental Protection Agency (EPA).
The original October 2023 rule established a one-time reporting requirement covering PFAS manufactured or imported from January 1, 2011 through December 31, 2022.
Depending on the applicable requirements, reportable information can include:
- Chemical identity
- Manufacturing and import activity
- Production and import volumes
- Uses
- Byproducts
- Disposal
- Worker, consumer and environmental exposure
- Available health and environmental effects information
The requirement is therefore broader than determining whether a product contains PFAS.
For the wider product-compliance context, see PFAS compliance for product manufacturers.
Who may need to report under TSCA Section 8(a)(7)?
The rule applies to entities that fall within the applicable TSCA definitions and have manufactured, including imported, PFAS within the reporting scope.
For a product manufacturer or discrete manufacturer, this distinction matters.
A company may purchase:
- PFAS-containing components
- Materials
- Assemblies
- Finished articles
- Products from suppliers
without that fact alone establishing that the company manufactured or imported the PFAS for purposes of Section 8(a)(7).
EPA distinguishes relevant manufacturing and importing activities from simply purchasing a component containing PFAS.
Companies should therefore assess their actual activities against the current EPA requirements.
What is the current TSCA PFAS reporting deadline?
The previously announced October 13, 2026 deadline should not be presented as the current operative deadline.
EPA's April 2026 action moved the start of the reporting period to 60 days following the effective date of the forthcoming revision to the PFAS Section 8(a)(7) rule.
This means compliance teams should not build their current reporting calendar around an older fixed deadline.
Before preparing or submitting information, verify:
- Whether the company is covered
- The current reporting scope
- The applicable reporting period
- The submission deadline
- Current EPA reporting instructions
The EPA TSCA Section 8(a)(7) PFAS reporting page should be treated as the current reference point.
What changed in the TSCA PFAS reporting requirements?
EPA has been reviewing both the scope and implementation of Section 8(a)(7).
In November 2025, EPA proposed changes that would modify the reporting requirements for certain categories, including potential changes relating to:
- Certain PFAS in mixtures and products
- Imported articles
- Byproducts
- Impurities
- Research and development chemicals
- Non-isolated intermediates
These were proposed changes, not final requirements. Product compliance teams should not treat a proposed exemption or exclusion as an established regulatory exception until EPA finalises the relevant rule.
What information may need to be reported?
The reporting dataset can include several categories.
Chemical identity
Depending on the requirement, this may include:
- Chemical name
- CAS number where applicable
- Other identifying information
- Information needed to identify the PFAS
Manufacturing and import information
Relevant records may include:
- Manufacturing activity
- Import activity
- Manufacturing sites
- Quantities
- Reporting years
Uses
Companies may need to identify the uses and functions associated with the PFAS.
For discrete manufacturers, this can require connecting:
PFAS → material → component → product → use
rather than keeping chemical information separate from product records.
Byproducts and disposal
The applicable reporting information may include byproducts, disposal and relevant environmental release or exposure information.
Exposure information
Information relating to worker, consumer and environmental exposure may also be relevant.
Health and environmental information
Available information concerning health and environmental effects may need to be included.
The exact reporting fields should be assessed against the current EPA requirements.
How should product manufacturers identify PFAS for TSCA reporting?
Start with the company's own manufacturing and importing activities.
Relevant sources may include:
- Chemical inventories
- Supplier information
- Material declarations
- Product specifications
- Bills of materials
- Purchasing records
- Manufacturing records
- Import documentation
- Historical product records
A useful traceability structure is:
Supplier → Material → Component → BOM → Product → PFAS → Regulatory assessment
This does not mean every PFAS identified in a BOM creates a TSCA Section 8(a)(7) reporting obligation.
The purpose is to establish enough traceability to determine:
- What PFAS are relevant
- Where they occur
- How the company obtained or manufactured them
- Whether the company's activity falls within the applicable TSCA scope
- What information is required
For supplier-data collection and validation, see PFAS supplier chemical transparency.
How should companies handle historical PFAS data?
The original rule covers manufacturing and importing activity dating back to 2011, making historical information particularly important.
Product manufacturers with long product lifecycles may need to reconstruct information from:
- Legacy BOMs
- Discontinued products
- Historical supplier declarations
- Archived material specifications
- Purchasing records
- Import records
- Manufacturing records
- Previous compliance assessments
Rather than collecting documents without a defined purpose, map each reporting requirement to the internal or external source that can provide the information.
What if PFAS information is missing?
Missing information should not automatically be treated as confirmation that PFAS are absent.
A compliance team can distinguish between:
Confirmed — available evidence establishes the relevant information.
Supplier evidence available — supplier information has been received but still requires assessment.
Unknown — available records do not establish the required information.
Not applicable — the company has assessed the requirement and determined that it does not apply.
This prevents incomplete historical or supplier data from being converted into unsupported compliance conclusions.
How should supplier information support TSCA reporting?
Supplier information can help product manufacturers identify PFAS in materials and components and reconstruct historical product information.
However, a supplier declaration does not independently determine the company's TSCA reporting obligation.
The company should establish:
What did we manufacture or import?
When did the activity occur?
Which PFAS were involved?
Does the activity fall within the applicable reporting scope?
What information is required?
Supplier data is therefore an important evidence source, but the reporting determination remains specific to the reporting entity and applicable TSCA requirements.
See PFAS supplier chemical transparency.
How should companies prepare while EPA revises the rule?
The current timing gives product manufacturers and importers an opportunity to prepare their underlying data before the revised reporting period begins.
1. Determine potential reporting scope
Review historical manufacturing and importing activities.
2. Identify relevant PFAS
Use internal records, supplier information and historical documentation.
3. Build the reporting population
Establish which PFAS and activities may fall within the applicable scope.
4. Map the required information
Create a structured dataset covering the information relevant to the reporting requirements.
5. Resolve data gaps
Prioritise missing chemical identity, volume, use, site, import and other information.
6. Validate the data
Cross-check supplier, purchasing, manufacturing and import records.
7. Preserve evidence
Maintain the records supporting reported information and compliance decisions.
8. Recheck the final rule
Once EPA finalises its revision, reassess the scope, exemptions, reporting period, deadline and reporting fields.
TSCA PFAS reporting vs product PFAS compliance
These are related but separate regulatory questions.
TSCA Section 8(a)(7)
The question is:
Does the company's manufacturing or importing activity fall within the TSCA PFAS reporting requirements?
Product PFAS compliance
The question is:
Does a product, material or component meet the PFAS requirements applicable to the markets where it is sold or used?
A product manufacturer may therefore need both assessments.
For example:
Product → Material → Component → PFAS → Product restriction assessment
can sit alongside:
Company activity → Manufacture/import → PFAS → TSCA reporting assessment
Keeping these workflows separate prevents a product-level PFAS finding from being incorrectly treated as a TSCA reporting conclusion.
For the European regulatory side, see EU PFAS restriction.
Common TSCA PFAS reporting mistakes
Assuming PFAS in a purchased component automatically creates a reporting obligation
The relevant question is the company's manufacturing or importing activity under TSCA.
Using an old reporting deadline
EPA has changed the reporting schedule. The April 2026 action tied the reporting-period start to the effective date of the forthcoming rule revision.
Treating proposed exemptions as final
The November 2025 changes were proposed. They should not be treated as final exclusions until incorporated into the applicable final rule.
Treating supplier declarations as the final TSCA determination
Supplier information supports the assessment but does not independently establish the company's reporting obligation.
Mixing TSCA reporting with product restrictions
TSCA reporting and product-level PFAS restrictions are different regulatory questions.
Failing to preserve historical evidence
Historical records can be important when establishing reporting information and supporting compliance decisions.
How does TSCA Section 8(a)(7) fit into global PFAS compliance?
TSCA Section 8(a)(7) is one part of the wider PFAS regulatory landscape.
Product manufacturers selling internationally may also need to assess:
- EU PFAS restrictions under REACH
- Canadian PFAS reporting requirements
- Japanese PFAS controls
- US state PFAS requirements
- Product-specific chemical restrictions
See EU PFAS restriction, Japan PFAS requirements, and Canada PFAS reporting requirements.
TSCA Section 8(a)(7) preparation checklist
Before preparing a submission, confirm that you have: