The TSCA Section 8(a)(7) Rule affects a broad range of manufacturers and importers; it’s no surprise we field frequent questions about its scope, provisions, and exceptions.

What’s the new ruling?

The TSCA Section 8(a)(7) Rule mandates manufacturers (including importers) of per- and polyfluoroalkyl substances (PFAS) since January 1, 2011, to report specific information to the EPA. This rule is part of the Toxic Substances Control Act (TSCA) and aims to gather data on the production, use, and disposal of PFAS. The full ruling is available here.

Does my brand need to report?

Any person or entity that has manufactured and/or imported PFAS since January 1, 2011, must report. This includes those who incorporated PFAS into products—but excludes those who only processed, used, or disposed of PFAS unless they also manufactured it.

What do I need to report?

For each year from 2011 to 2022, the following information must be reported to the extent "known or reasonably ascertainable" by the manufacturer—including data in possession or control and what a reasonable person in the same situation might be expected to know. There are two forms: one for domestically manufactured products, and one for imported products. The full reporting form, required for manufacturers, requests the following fields:

• Chemical Identity, Chemical Identification Number, Trade/Common Name, Molecular Structure, Import Production Volume, Industrial Processing and Use, Consumer and Commercial Use, Production Information, Byproduct Descriptions, Environmental and Health Effects, Exposure Data, and Disposal Information.

An abbreviated form for importers requires the following information:

• Chemical Identity, Chemical Identification Number, Trade/Common Name, Molecular Structure, Import Production Volume, Industrial Processing and Use, and Consumer and Commercial Use

How and where do I report?

The EPA is developing a new reporting tool for this rule hosted on CDX with other chemical information systems reporting tools.

Snaplinc Consulting’s PFAS Reporter Pro™ compliance app automates reporting. The tool walks importers through the process of due diligence and supports gathering and collection of “known to or reasonably ascertainable” information, then automates the documentation of due diligence with fillable forms. Importers will then be prepared to submit this compiled reporting to the EPA CDX system.

PFAS Reporter Pro streamlines compliance with step-by-step guidance, compiling over 300 pages of EPA rulings into one easy-to-use data preparation platform.

What’s the deadline?

The reporting window opens on July 11, 2025 and closes Jan 11, 2026 for most submitters.

Small manufacturers reporting exclusively as article importers must report from July 11, 2025 to July 11, 2026.

Where do I start?

If you’re an importer, fill out the PFAS Reporter Pro™ questionnaire to access a free risk assessment. This will highlight the product categories affected by the ruling and focus information gathering efforts on the high-risk products.

Next, use the PFAS Reporter Pro™ automated compliance platform to gather all necessary information well ahead of the 2026 deadlines.

If you’re not an importer but a manufacturer, schedule a free consultation call with Snaplinc’s experienced team to outline a compliance strategy ahead of the 2026 deadlines.