Research and Development (R&D) Exemption – PFAS

The R&D exemption, proposed in EPA’s November 2025 revision to TSCA 8(a)(7), would exempt PFAS manufactured in small quantities solely for research and development purposes from reporting obligations. This recognizes that R&D-scale PFAS production is typically exploratory and involves minimal quantities.

EPA November 2025 Proposed Rule (90 FR 50923); TSCA §3(2)(B); 40 CFR Part 705.

The R&D exemption is important for pharmaceutical, chemical, and materials research organizations that handle small quantities of PFAS experimentally. Without it, even laboratory-scale PFAS synthesis for analytical standards would trigger the same reporting requirements as large-scale manufacturing. Companies should document the R&D nature and small-scale quantities.

A university research lab synthesizes 50 grams of a novel fluorinated polymer for materials characterization research. Under the proposed R&D exemption, this small-quantity synthesis for purely scientific purposes would be exempt from TSCA 8(a)(7) reporting.