US EPA Delays PFAS Mandatory Reporting Deadline for Third Time, Granting Businesses Additional Nine-Month Preparation Period

On April 8, 2026, Lee Zeldin, Administrator of the U.S. Environmental Protection Agency (EPA), signed the final rule, further postponing the initiation date for per- and polyfluoroalkyl substances (PFAS) data reporting obligations under Section 8(a)(7) of the Toxic Substances Control Act (TSCA) to January 31, 2027. This marks the third extension since EPA established this rule in 2023.

Background

October 11, 2023: EPA finalized the PFAS reporting rule, requiring entities that manufactured (including imported) PFAS or PFAS-containing articles since January 1, 2011, to report detailed information to EPA
Originally scheduled submission period: Beginning November 12, 2024
First extension: September 5, 2024 – delayed to July 11, 2025 due to delays in developing the electronic reporting system (CDX)
Second extension: May 13, 2025 – delayed to April 13, 2026 due to continued IT development delays

Key Modifications in This Final Rule

Item	Original Requirement	New Requirement
Submission period start date for standard reporters	April 13, 2026	January 31, 2027, or 60 days after the date specified in 40 CFR 705.20(c), whichever is earlier
Submission period start date for small article importers	April 13, 2026	January 31, 2027, or 60 days after the date specified in 40 CFR 705.20(c), whichever is earlier
Duration of submission period	6 months (until October 13, 2026)	6 months (standard reporters) / 12 months (small article importers)

Important Notes

This rule adjustment only modifies the submission period start date and does not involve the submission period end date or other substantive modifications
EPA plans to issue a subsequent final rule before January 31, 2027, to address other issues raised in the November 2025 proposal (such as exemption clauses, etc.)
The rule adopts a severability clause design: if the "60-day period" is overturned in judicial review, the fallback date of January 31, 2027 remains valid; conversely, the same applies

About CIRS

Established in 2007, the CIRS Group is a leading product safety and regulatory consulting firm. CIRS has branches in the Republic of Ireland, South Korea, the United States, the United Kingdom, Japan, and China. CIRS Group utilizes its technical expertise, various resources, and international network to provide one-stop compliance services from regulatory compliance, laboratory testing, R&D to data services across multiple industries. This includes chemicals, cosmetics, food and food beverages, medical devices, agrochemical products, disinfectants, and consumer goods. It helps clients gain a competitive advantage by reducing business risks associated with regulatory affairs.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further Information

EPA

We have launched a LinkedIn newsletter to keep you up to date on the latest developments across the chemical industry including food and FCMs and personal and home care.