EPA Delays Start of PFAS Reporting Period Until July 2025

As previously reported, the U.S. Environmental Protection Agency (EPA) issued a final rule in October 2023 requiring extensive reporting on per- and polyfluoroalkyl substances (PFAS) that were manufactured or imported between 2011 and 2022, or PFAS-containing articles that were imported during this period. The rule became effective on November 13, 2023, and includes a one-year collection period and a six-month reporting period for most entities. That reporting period was originally set to run from November 12, 2024 through May 8, 2025.

On September 5, EPA issued a direct and final rule to extend the start of the reporting period to July 11, 2025. The reporting period for most entities will end on January 11, 2026; however, some small article importers will have until July 11, 2026 to report.
 
EPA cited resource constraints and competing statutory priorities, resulting in a significantly reduced IT operating budget in Fiscal Year 2024 as the basis for delaying the start of the reporting period. The Agency acknowledged that the software application that will collect the PFAS data from submitters will not be ready by the original November 2024 reporting date, and thus, it would be impossible for submitters to report the requested information to EPA at that time.

This direct and final rule is effective November 4, 2024, unless EPA receives adverse comments.