TSCA §8(a)(7) PFAS reporting rule at 40 CFR Part 705 implements the FY2020 National Defense Authorization Act PFAS amendment. Scope — any entity that 'manufactured' (including imported) any PFAS (substance, mixture, or article containing PFAS) for any commercial purpose at any time between January 1, 2011 and December 31, 2022. PFAS definition (40 CFR 705.3) — structural: substances containing at least one fully fluorinated carbon meeting the per-/polyfluoroalkyl criterion; current EPA-published list ~1,462 substances plus any structural match. No de minimis, no volume threshold, no article exemption (imported finished goods, components, packaging, lubricants, coatings, semiconductors, textiles, cookware, medical devices all in scope). Limited exemptions — R&D under §705.10; municipal solid-waste landfill operators; certain byproduct categories. Reporting window — July 11, 2025 to October 13, 2026 standard; April 13, 2027 for small manufacturers ($12M revenue test) of article-only PFAS imports. Per submission per substance per year (2011-2022) report — chemical identity (CASRN, EPA accession, structural identifier for confidential/UVCB), categories of use (industrial processing, commercial product, consumer product, article import), production/import volumes, byproducts, environmental and health-effects data 'known or reasonably ascertainable' (§8(a) diligence standard — corporate knowledge plus reasonable inquiry of suppliers and review of public information), worker exposure data, disposal methods. Joint submissions — primary submitter (often PFAS manufacturer) files identity/effects/exposure once; downstream importers reference joint-submission number and file only their volumes and use categories. CBI under TSCA §14 — substantiated specific-harm-from-disclosure claims with redacted-and-unredacted versions; generic claims fail. Penalties under TSCA §16 — up to ~$53,000 per violation per day (annually adjusted), each PFAS-year combination treated as a separate violation. Filing via EPA Central Data Exchange (CDX) Chemical Information Submission System (CISS).

Regulatory anchors

40 CFR Part 705
15 USC §2607(a)(7)
FY2020 NDAA §7351
TSCA §14 CBI
TSCA §16 penalties

Industries that live with this

Chemicals Consumer Products Medical Devices Plastics & Resins

How V5 handles it

Score your compliance gap — then download the validation pack.

A guided self-assessment walks you against the regulator clauses that apply to your industry. The validation pack — IQ/OQ/PQ scripts, traceability matrix, risk assessment, intended-use statement — generates from the same evidence so you can hand it to an auditor on day one.

Supplier portal — chase nothing. Score everything.

Suppliers log in, see what you need, submit it against your spec, and watch their scorecard. SCARs are raised, replied to and closed in the portal — not in your inbox.

Document control with hard kiosk-level training enforcement.

Versioned SOPs are only useful if operators are actually trained on the current version. V5 enforces it at the kiosk.