The Environmental Protection Agency (EPA) just issued a direct final rule amending reporting deadlines for per- and polyfluoroalkyl substances (PFAS) under the Toxic Substances Control Act (TSCA).

As described in our November 2025 client alert, the Trump Administration’s EPA is making significant changes to the rule that requires entities that manufacture or have manufactured PFAS in any year since January 1, 2011, to submit a one-time comprehensive report regarding PFAS uses, production volumes, byproducts, disposal, exposures, and environmental or health effects.

EPA has again bumped back the start of the data submission period (initially November 12, 2024 and then July 11, 2025) to January 31, 2027, or 60 days following the effective date of EPA’s forthcoming final rule on the proposed revisions to the substantive requirements of the PFAS Reporting Rule, whichever is earlier.