TSCA Section 8(a)(7) PFAS Reporting Readiness
Test each substance against the structural definition, gather what you know back to 2011 and be ready when the window opens.
In Short
- One-time report, back to 2011.
- Window opens by 31 Jan 2027.
- Keep records 5 years.
The Chemical Manufacturing Guide
Approved formulas. Tested batches. Correct labels out the door.
- Which rules reach your plant
- Raw material to store
- Charge, watch, adjust, release
We ask for your name and email so we can handle this request. The full guide then opens on this site, ready to translate, print or save. Privacy policy. Practical orientation, not legal advice; your quality unit decides which rules apply.
UltimateFree guide
The Chemical Manufacturing Guide
Approved formulas. Tested batches. Correct labels out the door.
40 CFR Part 705 requires a one-time report to EPA from anyone who manufactured a PFAS for commercial purposes in any year from 2011 through 2022, and Part 705 brings importers of PFAS in articles into the report. This guide covers scope, the structural test, what to report, timing and records. It is orientation, not legal advice. Sources checked 4 Oct 2026.
Who has to report
Section 705.10 covers any person who manufactured a PFAS for commercial purposes at any time from 1 January 2011 through the end of the last calendar year before 13 November 2023, which is 2022. Section 705.18 makes clear that importers of articles containing PFAS who meet 705.10 are in scope and gives them a streamlined form.
More on who has to report
Section 705.12 excludes only two activities: importing municipal solid waste for disposal or destruction, and federal agency imports with no commercial advantage. Read the definitions in 705.3, which also pull in 40 CFR 704.3, before deciding a site is out of scope.
Is it a PFAS? The structural test
Part 705 does not use a list. Under 705.3 a PFAS is any chemical substance, or mixture containing one, whose structure contains at least one of three sub-structures: a saturated CF2 group bonded to a saturated CF carbon carrying further substituents; two CF2 groups bridged by an ether oxygen; or a carbon carrying two CF3 groups.
The three sub-structures (705.3)
| Sub-structure | In words |
|---|---|
| R-(CF2)-CF(R')R'' | Saturated CF2 bonded to a saturated CF carbon |
| R-CF2OCF2-R' | Two CF2 groups bridged by an ether oxygen |
| CF3C(CF3)R'R'' | A carbon carrying two CF3 groups |
- R-(CF2)-CF(R')R''
- In words
- Saturated CF2 bonded to a saturated CF carbon
- R-CF2OCF2-R'
- In words
- Two CF2 groups bridged by an ether oxygen
- CF3C(CF3)R'R''
- In words
- A carbon carrying two CF3 groups
More on is it a PFAS? The structural test
A chemist should check each candidate structure against the exact wording in 705.3, and record who decided and on what evidence. Supplier declarations help, but a trade name alone does not answer the question.
What the report contains and how far back it goes
Under 705.15, reporters give company and site information, including the highest-level US parent company, an authorized official who can sign, a technical contact and site identifiers, then chemical-specific information for each PFAS at each site for each year since 2011. Identity is reported by CASRN, TSCA Accession Number or low-volume exemption number.
More on what the report contains and how far back it goes
Information is required to the extent known to or reasonably ascertainable by the reporter, and reasonable estimates may be used where actual data are not. If a supplier holds the identity as confidential, 705.15 allows a generic name and a joint submission.
Article importers and small R&D volumes
Section 705.18(a) lets an importer of an article containing PFAS use a streamlined form for each year since 2011 in which the PFAS was imported in an article. Company and site information is still required in full, with chemical-specific information to the extent known or reasonably ascertainable.
Worked Example: Article File AR-118
More on article importers and small R&D volumes
Section 705.18(b) offers a similar route for PFAS manufactured only as research and development substances at no more than 10 kilograms per year. The streamlined form narrows what is asked; it does not remove the duty to look for the information you can reasonably find.
Timing, Duplicates and Records
As amended on 13 April 2026, 705.20 opens the submission period on 31 January 2027, or 60 days after a date EPA announces in the Federal Register if that is earlier, and runs for six months. Article-only importers that are small manufacturers under 40 CFR 704.3 get twelve months.
Submission windows (705.20)
- 31 Jan 2027Period opens, or 60 days after an earlier date EPA announces
- + 6 monthsGeneral period closes
- + 12 monthsCloses for small manufacturers reporting only article imports
- + 5 yearsRecords may be discarded after this (705.25)
More on timing, Duplicates and Records
Section 705.22 lets a reporter point to information already submitted to EPA instead of repeating it. Under 705.25, records documenting what was reported must be kept for five years from the last day of the submission period. Confidentiality claims are made at submission and certified by an authorized official under 705.30.
Questions
Is this a recurring report?
No. Part 705 describes a one-time submission covering each year from 2011 through 2022. Check EPA's Federal Register notices for any later change to the submission period.
Do we report PFAS in imported finished goods?
Importers of articles containing PFAS who meet 705.10 are in scope and may use the streamlined article form in 705.18(a), reporting to the extent they know or can reasonably ascertain.
What if our supplier will not disclose the chemical identity?
Section 705.15 allows a generic name or description and a joint submission in which the supplier provides the identity to EPA directly.
How long do we keep records?
Five years beginning on the last day of the submission period (705.25).
Practical orientation, not legal advice. Rules differ by jurisdiction; your quality and compliance team decides what applies.
Keep reading
TSCA Section 5 PMN: Who Files, the 90-Day Review and Notice of Commencement
FTC Made in USA Labels (16 CFR 323) and Endorsement Disclosures
TSCA Chemical Data Reporting (40 CFR 711): Thresholds, Timing, Records
EPA Pesticide Establishment Readiness: Registration, Annual Reports and Records
Pesticide Product Registration: FIFRA Section 3 and EU 1107/2009
Bisphenols and Phthalates in Plastics: EU 2024/3190, FDA Abandoned Uses and CPSC Limits