On November 13, 2025, the U.S. Environmental Protection Agency (EPA) issued a proposed rule to amend the Toxic Substances Control Act (TSCA) Section 8(a)(7) regulation for reporting and recordkeeping requirements for perfluoroalkyl and polyfluoroalkyl substances (PFAS). 90 Fed. Reg. 50923. As reported in our October 3, 2023, memorandum, the final rule requires manufacturers (including importers) of PFAS and PFAS-containing articles in any year since 2011 through 2022 to report information related to chemical identity, uses, volumes made and processed, byproducts, environmental and health effects, worker exposure, and disposal to EPA. The proposed rule would incorporate exemptions to the scope of reportable manufacturing activities for a de minimis exemption of 0.1 percent; imported articles; byproducts; impurities; research and development (R&D); and non-isolated intermediates. According to EPA’s proposed rule, these exemptions “would maintain important reporting on PFAS, consistent with statutory requirements, while exempting reporting on activities about which manufacturers are least likely to know or reasonably ascertain.” Comments are due December 29, 2025. According to the proposed rule, comments on the information collection provisions of this proposed rule under the Paperwork Reduction Act (PRA) must be received by the Office of Management and Budget’s Office of Information and Regulatory Affairs (OIRA) on or before December 15, 2025. For more information, please read the full memorandum.

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