EPA to Require One-Time Reporting of PFAS Use by 2025
The EPA will require importers and manufacturers to report on their use of perfluoroalkyl and polyfluoroalkyl substances (PFAS) for each year since 2011, it said in an Oct. 11 final rule. By May 13, 2025, importers and manufacturers must electronically submit information on uses, production volumes, byproducts, disposal, exposures, and existing information on environmental or health effects for any PFAS importers or manufactured since 2011. Small importers will have six months longer, until Nov. 13, 2025, EPA said.
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That’s up from the proposed rule’s one year after the effective date of the eventual final rule (see 2106250046). Other changes since the proposed rule include an expanded definition of PFAS, streamlined options for importers of R&D substances below 10 kg, and changes to the data elements required in the one-time submissions, EPA said.
“EPA’s new PFAS reporting rule will impact companies in a wide range of industries, including companies that import machinery and equipment containing gaskets, tubing, electrical wiring, composite materials, printed circuit boards, membranes and other types of components that are frequently made with fluoropolymers,” law firm Crowell said in a client alert last week.
“To ascertain the information required to be reported under this rule, companies may be required to navigate multi-tiered global supply chains to identify which components of a manufactured article contain PFAS compounds, the specific identities those PFAS compounds, and the quantities of those compounds that might be present in an article. This is a highly complicated and time-consuming process, and the obligation to collect this information for every year since 2011 makes this task even more complex,” Crowell said, urging affected companies to “act without delay.”