PFAS Reporting Proceeds: 2025 EPA Update

The Environmental Protection Agency (EPA) is ramping up its efforts to limit contamination from per- and polyfluoroalkyl substances (PFAS). In late April, EPA Administrator Lee Zeldin released a new framework including a significant number of actions covered PFAS reporters should carefully consider when preparing for reports. New information for companies covered under the Toxic Substances Control Act (TSCA) includes:

• EPA strategies to strengthen PFAS data collection efforts.

• Intent to make data collection less burdensome for smaller entities.

• Continuation of the PFAS reporting timeline.  

PFAS Reporting Will Proceed 

Part of the new suite of actions is an intent to apply section 8(a)7 of TSCA to efficiently collect necessary from reporters “without overburdening small businesses and article importers.” The takeaway here is that reporting for covered companies will still proceed, although specific changes to the scope and timeline have not been announced. 

The reporting window for data submission opens on July 11, 2025, and the majority of reporters will have to submit their complete reports by January 11, 2026. The exception is small businesses who are reporting solely on PFAS contained in imported articles, who have until July 11, 2026 to submit reports.  

The First Wave of PFAS Updates 

The EPA’s new actions are designed to tackle PFAS in a coordinated effort from all of the Agency’s program offices. The actions fall under three principles: strengthening the science, fulfilling statutory obligations and enhancing communication, and building partnerships. The goal of the actions is to create a foundational toolbox and provide the investment required to help states and individual communities deal with PFAS contamination. The EPA announcement outlines the plan as follows: 

Strengthening the Science   

• Designate an agency lead for PFAS to better align and manage PFAS efforts across agency programs   

• Implement a PFAS testing strategy under Toxic Substances Control Act (TSCA) Section 4 to seek scientific information informed by hazard characteristics and exposure pathways    

• Launch additional efforts on air related PFAS information collection and measurement techniques related to air emissions    

• Identify and address available information gaps where not all PFAS can be measured and controlled   

• Provide more frequent updates to the PFAS Destruction and Disposal Guidance—changing from every three years to annually—as EPA continues to assess the effectiveness of available treatment technologies   

• Ramp up the development of testing methods to improve detection and strategies to address PFAS  

Fulfilling Statutory Obligations and Enhancing Communication   

• Develop effluent limitations guidelines (ELGs) for PFAS manufacturers and metal finishers and evaluate other ELGs necessary for reduction of PFAS discharges  

• Address the most significant compliance challenges and requests from Congress and drinking water systems related to national primary drinking water regulations for certain PFAS   

• Determine how to better use RCRA authorities to address releases from manufacturing operations of both producers and users of PFAS   

• Add PFAS to the Toxic Release Inventory (TRI) in line with Congressional direction from the 2020 National Defense Authorization Act   

• Enforce Clean Water Act and TSCA limitations on PFAS use and release to prevent further contamination    

• Use Safe Drinking Water Act authority to investigate and address immediate endangerment   

• Achieve more effective outcomes by prioritizing risk-based review of new and existing PFAS chemicals   

• Implement section 8(a)7 to smartly collect necessary information, as Congress envisioned and consistent with TSCA, without overburdening small businesses and article importers.   

• Work with Congress and industry to establish a clear liability framework that operates on polluter pays and protects passive receivers   

Building Partnerships    

• Advance remediation and cleanup efforts where drinking water supplies are impacted by PFAS contamination   

• Work with states to assess risks from PFAS contamination and the development of analytical and risk assessment tools   

• Finish public comment period for biosolids risk assessment and determine path forward based on comments   

• Provide assistance to states and tribes on enforcement efforts    

• Review and evaluate any pending state air petitions    

• Resource and support investigations into violations to hold polluters accountable  

More detailed guidance and updates may be released in the future, so it’s essential to keep an eye on EPA announcements going forward.   

Best Practices for PFAS Reporting 

As the EPA works to create a more comprehensive mitigation strategy for PFAS, companies with any PFAS in their products need to prepare for more stringent scrutiny and enforcement. Key readiness strategies include: 

• Conducting a PFAS inventory to gain clarity on usage, releases, and storage. 

• Review TSCA reporting procedures to ensure thresholds are correctly applied. 

• Enhance recordkeeping and data management to meet increased EPA standards for transparency and accuracy.    

How Snaplinc Consulting Can Help 

PFAS reporting under TSCA is a challenging undertaking, with the reporting instructions consisting of 156 pages. Snaplinc Consulting’s PFAS Reporter Pro tool makes Section 8(a)(7) reporting a streamlined process, allowing your company to draft a comprehensive report and avoid costly penalties.  

Our experts are ready supply specialized expertise in PFAS compliance and assist in navigating these complex regulations while ensuring your products’ safety through comprehensive supply chain assessments and more.  

Get in touch with your PFAS questions or schedule a consultation with Snaplinc today.