Are you ready for the 2027 U.S. EPA PFAS reporting mandate?

October 23, 2026

US EPA Reporting Rule Submissions on laptop representing Sagentia Regulatory's services

As the reporting window for the U.S. Environmental Protection Agency’s (EPA) PFAS Reporting Rule approaches, attention is increasingly turning to the practical challenge of gathering and validating the information required for reporting.

Under EPA’s April 2026 final rule, reporting is expected to begin on January 31, 2027, or 60 days after the effective date of a forthcoming final rule revising the PFAS reporting requirements, whichever occurs earlier. While EPA is considering revisions to the rule, organizations should continue preparing based on the current requirements.

Who may be affected by EPA’s PFAS reporting requirements?

The current rule applies to companies that manufactured (including imported) PFAS for a commercial purpose at any time between January 1, 2011, and December 31, 2022, including certain importers of PFAS-containing articles.

The rule may be relevant to:

Chemical manufacturers
Importers of chemical substances
Companies importing products, articles or components containing PFAS
Organizations with complex global supply chains
Companies that have acquired, divested or restructured businesses during the reporting period

What information must be reported?

Required information generally includes:

Chemical identity
Production volumes
Uses and categories of use
Byproducts
Environmental and health effects information
Worker exposure information
Disposal practices and releases to the environment

These reporting obligations remain in effect unless and until EPA finalizes revisions to the rule.

Why is PFAS reporting challenging?

For many organizations, the challenge lies not in understanding the reporting requirements, but in gathering and validating the information needed to support them.

Companies may need to compile information spanning more than a decade of manufacturing, import and supply chain activities. Identifying PFAS-containing products, obtaining information from suppliers, validating historical records and addressing data gaps can be among the most resource-intensive aspects of compliance, particularly for organizations with complex product portfolios or global supply chains.

How can Sagentia Regulatory help?

Sagentia Regulatory recognizes the challenges posed by this extensive reporting requirement. Having assisted clients with PFAS reporting and similar reporting under TSCA, we can help you develop an efficient approach to gathering, managing and reporting the information required by EPA, including:

Tools to help collect and manage information required for PFAS reporting
Guidance on PFAS reporting requirements
Preparation of reporting forms and assistance with TSCA submissions
Support in protecting Confidential Business Information (CBI)

Do you have the information you need for PFAS reporting?

Gathering, validating and managing more than a decade of manufacturing, import and supply chain data can be a significant compliance challenge.

Speak to our PFAS and TSCA experts about your reporting strategy

PFAS Reporting Rule: Frequently asked questions

When does the EPA PFAS reporting window open?

Under EPA’s April 2026 final rule, reporting is expected to begin on January 31, 2027, or 60 days after the effective date of EPA’s forthcoming final rule revising the PFAS reporting requirements, whichever occurs earlier. Companies should monitor EPA’s ongoing rulemaking activities, as the timing and reporting requirements may be affected by future revisions to the rule.

Does EPA’s PFAS reporting rule apply to imported articles?

Potentially. EPA’s TSCA Section 8(a)(7) PFAS Reporting Rule applies to certain importers of PFAS-containing articles. Companies should evaluate their products, supply chains and import activities to determine whether reporting obligations apply.

What records should companies gather for PFAS reporting?

Companies may need to gather historical information relating to PFAS manufactured or imported between 1 January 1, 2011 and December 31, 2022, including data on chemical identity, production volumes, uses, worker exposure and disposal practices. Depending on the organization, this information may reside across multiple business functions, suppliers and legacy systems.

How long does it take to prepare for PFAS reporting?

The time required depends on the complexity of an organization’s operations, products and supply chain. For many companies, the most time-consuming aspect is gathering and validating historical information, particularly where records span multiple suppliers, business units or acquired businesses.