TSCA §8(a)(7) PFAS reporting rule
TSCA Section 8(a)(7) PFAS One-Time Reporting Rule under 40 CFR Part 705 · TSCA §8(a)(7) · 40 CFR 705 · PFAS reporting rule · EPA PFAS one-time report
Term — TSCA Section 8(a)(7) PFAS one-time reporting rule: ePA's one-time retrospective PFAS reporting rule under TSCA §8(a)(7) (40 CFR Part 705) — every US manufacturer or importer of any PFAS (substance or article) at any time between January 1, 2011 and December 31, 2022 must file via CDX/CISS during reporting window July 11, 2025 to October 13, 2026 (April 13, 2027 for small article importers <$12M revenue); no de minimis, no volume threshold, no R&D exemption beyond narrow §705.10 carve-out; ~1,462 listed PFAS plus any structural-definition match; per-year per-substance reporting of identity, use category, volume, byproducts, effects (known or reasonably ascertainable), worker exposure, disposal; joint submissions and §14 CBI substantiation supported; TSCA §16 penalties up to ~$53,000/violation/day.
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).
- 40 CFR Part 705
- 15 USC §2607(a)(7)
- FY2020 NDAA §7351
- TSCA §14 CBI
- TSCA §16 penalties
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