TSCA PFAS Reporting Deadline Falls in 2027 for Chemical Importers

If your company imported a chemical at any point from 2011 to 2022, EPA's PFAS reporting rule asks what you knew about what was in it. Under the rule as it stands, the window to answer opens on January 31, 2027 at the latest, and the TSCA PFAS reporting deadline falls 6 months after that.

That date comes from EPA's April 13, 2026 rule, the 3rd time the start has moved. Congress added the requirement to TSCA in the defense bill for fiscal year 2020, and EPA's 2023 rule reaches back to every year from 2011 through 2022.

2 versions of the rule share a start date.

The rule in force is EPA's 2023 final rule. EPA estimated it would reach 131,410 respondents, and it set no minimum amount and no exemption for imported finished goods.

In November 2025, EPA proposed 6 exemptions, for imported articles, PFAS at or below 0.1%, byproducts, impurities, research and development, and non-isolated intermediates. Under that version, EPA estimates 255 firms would report, and 127,469 small companies that only imported articles would no longer be covered.

EPA expects to finish the new version before January 31, 2027. The proposal went through White House review before it was published. As of October 28, the final version isn't on the list of rules under that review.

Every importer has to search before it knows whether it reports.

The rule covers what a company knew, or could reasonably ascertain, about the PFAS it made or imported. EPA's own proposal says more companies will need to search their records than will end up reporting.

That search is the 12-year look-back, every import from 2011 through 2022 checked against the rule's definition of PFAS. EPA counts 1,462 known substances that meet that definition and says the count isn't the whole universe.

The 2 exemptions that remove the most companies, imported articles and the 0.1% level, don't cover a company that imported a PFAS chemical, or a mixture above 0.1%. That company has a look-back to do under either version.

3 parts of the rule are still open.

• Which version opens the window.

  If EPA finalizes the new rule first, reporting starts 60 days after it takes effect. If it doesn't, the window opens on January 31, 2027 under the rule in force. EPA says it will announce the date in the Federal Register.

• Which exemptions survive.

  EPA received nearly 600 unique comments, plus more than 8,500 from 2 mail-in campaigns, and may finalize all, some, or none of the changes.

• Whether the date holds.

  It has moved 3 times since 2023, twice because the reporting software ran late.

Start the look-back this quarter.

None of these steps depends on which version EPA finalizes.

1. 1

   List every import from 2011 through 2022.

   Purchasing and customs records, by year and by product.

   You leave withOne list to check.

2. 2

   Mark which were chemicals or mixtures, and which were finished goods.

   Finished goods are the imports the proposal would exempt.

   You leave withYour exposure under each version.

3. 3

   Find what was in each one.

   Where your file doesn't say, the supplier is the next place to ask.

   You leave withA composition on file for every line.

4. 4

   Write down what you checked and what you found.

   Reporters must keep records for 5 years after the window closes.

   You leave withA record of the search.