Article (under TSCA Section 8(a)(7))

Under the TSCA Section 8(a)(7) PFAS Reporting Rule (40 CFR Part 705), an “article” is a manufactured item that is formed to a specific shape or design during manufacture, where its end-use function is dependent in whole or in part upon its shape or design during end use. This includes finished goods, components, and subassemblies that contain or were manufactured using PFAS. Importers of articles containing PFAS are subject to reporting obligations under TSCA 8(a)(7), though the November 2025 proposed revisions would exempt imported articles from reporting.

40 CFR § 705.3 (definitions); TSCA Section 8(a)(7); EPA November 2025 Proposed Rule (90 FR 50923).

The inclusion of articles in the TSCA 8(a)(7) rule was one of its most expansive features. Any company that imported a finished product containing PFAS—from electronics to textiles to medical devices—between 2011 and 2022 would need to report. The November 2025 proposed revision would exempt imported articles, potentially removing 127,469 small businesses from reporting requirements. Companies should monitor the final rule (expected mid-2026) to confirm whether this exemption is adopted.

A U.S. electronics distributor importing circuit boards coated with PFAS-containing conformal coatings from Asia between 2011 and 2022 would currently be required to report under TSCA 8(a)(7). If the imported articles exemption is finalized, this distributor would no longer need to submit PFAS data for those imported boards.