A nine-month delay in reporting use of so-called “forever chemicals” shouldn’t be taken as a removal of the reporting requirement, says Assent’s Cally Edgren, who urges companies to use this time wisely.
A July federal deadline for reporting per- and polyfluoroalkyl substances (PFAS) has been delayed; the EPA has confirmed that the new reporting window for PFAS under Section 8(a)(7) of the Toxic Substances Control Act (TSCA) will now open April 13, 2026.
The agency’s Central Data Exchange (CDX) portal is not ready to meet demand, with system testing revealing issues that could have locked out users or corrupted uploads, and the agency will take more time to improve and stress-test the portal.
So, what does this mean? The majority of companies will now have until Oct. 13, 2026, to file — but smaller manufacturers that import articles will have until April 13, 2027. All in all, this will give manufacturers more runway to ramp up their program, but their requirements — and their workload — remain the same.
The delay buys some time, but manufacturers still need to be working urgently to meet their requirements.
No change to scope or requirements
The rule remains the same in practical terms. That means if a manufacturer made PFAS or brought it into the US between Jan. 1, 2011, and Dec. 31, 2022, they still have to report it — this applies to articles, byproducts, impurities, intermediates and maintenance chemicals. In other words, TSCA Section 8(a)(7) is still casting a very wide net — one that includes small businesses and article importers when their respective reporting windows open.
State PFAS rules
State laws have not been affected by the delay. Take Minnesota’s Amara’s Law, for example: Product prohibitions started phasing in Jan. 1, 2025, and the law aims to restrict the majority of items with intentionally added PFAS by 2032 unless they are deemed unavoidable by regulators.
And Minnesota isn’t alone. Other states are taking action to set strict drinking-water limits or outright restrict PFAS discharges in wastewater. Ultimately, this means manufacturers still have to do the hard work of navigating state requirements — requirements that are often more stringent than TSCA.
What’s next for manufacturers and importers?
The extension doesn’t offer companies a reprieve, and they should use this valuable time wisely. Strengthening existing compliance plans is key and that starts with mapping potential PFAS touchpoints such as coatings, insulators, O-rings, seals, surfactants, lubricants and process aids (which don’t always appear on bills of materials). Once that’s done, start asking suppliers for declarations and verifying claims. It’s better to do it early when response times are still manageable. Finally, do the work to ensure that data sets are clean because CDX templates don’t allow for conflicting information.
Beyond regulation
TSCA isn’t the only thing creating urgency around PFAS. In December 2022, 3M announced plans to exit PFAS manufacturing by the end of this year. That means that by 2026, many sources of PFAS (or 3M products that contain PFAS) could be dried up or very expensive. If companies want to continue using PFAS, they need to prepare for big changes to customer contracts, insurance policies and investor expectations that increasingly favor PFAS phase-outs.
Conclusion
Nine months is a short time when it comes to managing complex supply chains. As a result, not much has changed in terms of the need to collect PFAS data. The EPA is still spending resources on improving the submission portal, signaling the agency’s commitment to collecting this data. Couple that with growing state requirements and the shift away from PFAS production, and it’s clear that companies that take action now will be in a better position when the submission portal opens April 13, 2026, than those that wait for the next headline.
Cally Edgren is vice president of regulatory and sustainability at Assent. She is a proven compliance program leader with experience developing, communicating and executing company goals and strategies. She is a subject matter expert on product materials compliance, as well as market access certifications and has a background in program and process development to support regulatory compliance requirements. Cally possesses 30 years of experience in developing and managing global compliance programs at Rockwell Automation, Kohler Co. and Rayovac. 
