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Warner Norcross + Judd LLP is a corporate law firm with over 230 attorneys serving clients in nine offices throughout Michigan. Among the largest law firms in Michigan, Warner works in virtually all areas of business law.

Michigan Law Firm - Warner Norcross + Judd LLP

The U.S. Environmental Protection Agency (EPA) has issued a direct final rule that delays the opening of the data‑reporting window for per‑ and polyfluoroalkyl substances (PFAS) required under Section 8(a)(7) of the Toxic Substances Control Act (TSCA). Reporting was slated to begin July 11, 2025, but the EPA has extended the reporting window by another nine months. The reporting window now opens on April 13, 2026. Submissions will be due Oct. 13, 2026, for most manufacturers, and April 13, 2027, for small manufacturers who report exclusively as article importers.

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This extension gives manufacturers and importers additional time to assemble the extensive information the rule demands.

EPA cites the same reason for its previous extension of the TSCA PFAS reporting rule: The agency needs more time to prepare the web reporting application that will be used to collect TSCA data.

EPA also notes that it “is separately considering reopening certain aspects of the rule to public comment. The delayed reporting date ensures that EPA has adequate time to consider the public comments and propose and finalize any modifications to the rule before the submission period begins.” This is a critical opportunity for manufacturers and importers of PFAS-containing articles to lodge comments with EPA.

What the Rule Still Requires

The core obligations of the Oct. 2023 PFAS reporting rule remain unchanged — for now. Any entity that has manufactured or imported PFAS (or PFAS‑containing articles) since 2011 must submit one‑time electronic reports covering, among other things:

Chemical identity, uses and annual volumes.

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By‑products, disposal practices and worker exposure.

Known or reasonably ascertainable environmental and health effects.

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Given the breadth of data, reporting entities should not take their foot off the gas. Companies should launch (or resume) supplier outreach and review internal records to ensure they can collect the potentially massive amount of information necessary for reporting.

Warner’s Resources, Energy and Environmental Law Practice Group is actively assisting businesses in preparing for the TSCA PFAS reporting rule as well as emerging state PFAS regulations. For tailored guidance on how these extended deadlines affect your compliance strategy, contact Paul Beach or your Warner attorney.

Partner

Paul H. Beach

Regulatory and Compliance

Resources, Energy and Environmental Law

Manufacturers and Importers Win More Time as EPA Again Extends TSCA PFAS Reporting Deadlines

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Manufacturers and Importers Win More Time as EPA Again Extends TSCA PFAS Reporting Deadlines

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