Bergeson & Campbell, P.C. (B&C^®) is pleased to present the on-demand recording for “Determining PFAS Content in Your Supply Chain and Expanding Data Collection Practice,” a complimentary webinar covering the basics of the U.S. Environmental Protection Agency’s (EPA) reporting rule for per- and polyfluoroalkyl substances (PFAS). With Chemical Data Reporting (CDR) wrapping up this fall, companies still have time to gather the necessary information regarding PFAS to begin reporting as early as this November.

The fiscal year (FY) 2020 National Defense Authorization Act (NDAA) amended the Toxic Substances Control Act (TSCA) to require that all manufacturers (including importers) of PFAS and PFAS-containing articles in any year since 2011 report information related to chemical identity, uses, volumes made and processed, byproducts, environmental and health effects, worker exposure, and disposal to EPA. According to EPA, at least 1,462 PFAS that are known to have been made or used in the United States since 2011 will be subject to its October 2023 final reporting rule, but the actual number may be very much higher. The six-month reporting period will begin November 12, 2024, and end May 8, 2025. Small businesses that are solely reporting data on importing PFAS present as components in articles have an additional six months to report, until November 10, 2025.

In this webinar, Richard E. Engler, Ph.D., Director of Chemistry, B&C, and Lynn L. Bergeson, Managing Partner, B&C, reviewed what PFAS are reportable, what information is due and by when, why finished product importers are on the hook for reporting, why there is a 12-year look-back, and the all-important topic of how much diligence is due before concluding information is “not known or reasonably ascertainable.”