On October 11, 2023, EPA published its updated reporting and recordkeeping requirements for Per- and Polyfluoroalkyl Substances (PFAS) under the Toxic Substances Control Act (TSCA). Under these reporting and record keeping requirements any person/entity that manufactures/ed or imports/ed PFAS or articles that contain PFAS, in any year since January 1, 2011, must electronically report, by January 11, 2026, information regarding the articles or PFAS uses, production volumes, disposal, exposure, hazards, etc. Under this new requirement, no previous TSCA compliance interaction is required. This requirement will affect a large number of companies as it cast a broad net to include companies that import PFAS treated products or products in packaging containing PFAS or that have been treated with PFAS. The required reporting is to be done through EPA’s Central Data Exchange (CDX) which requires registration.
