Per- and Polyfluoroalkyl Substance Regulations and Toxic Substances Control Act


New and expanded federal, state, and international regulations regarding per- and polyfluoroalkyl substances (PFAS), are coming into force around the world. In the United States, industrial and manufacturing clients who use or make PFAS need to understand and comply with complex new reporting required by the United States Environmental Protection Agency’s (USEPA’s) Toxic Substances Control Act (TSCA).

The TSCA Section 8(a)(7) Reporting and Recordkeeping Rule for PFAS requires a one-time report by manufacturers or importers of any known or reasonably ascertainable PFAS substances subject to the Rule’s specific reporting criteria. Given the depth, breadth, and urgency of this requirement, it is important for businesses to have policies and procedures in place and to have an auditable paper trail to demonstrate due diligence regarding compliance with the Rule.

Build a Successful Approach with a Stepwise Strategy for PFAS Compliance


Geosyntec takes a pragmatic, stepwise approach to understanding applicability and supporting clients through due diligence and reporting. This method supports an efficient, documented, and defensible process for our clients faced with a May 8, 2025, reporting deadline.



For our clients managing PFAS and TSCA reporting, we often help in the following ways:

  • Building due diligence compliance plans and cross-functional teams
  • Providing on-demand technical consulting during due diligence
  • Collecting and interpreting PFAS chemistry and safety data
  • Communicating with and getting reliable information from suppliers
  • Monitoring and explaining domestic and international regulations for clients with global operations
  • Reviewing, providing QA/QC for, interpreting, and organizing any PFAS findings
  • Compiling and preparing reports for submission in 2025
  • Providing global perspective on PFAS findings throughout the supply chain (for example, understanding the implications of the EU REACH Annex XVII PFAS Restriction and risk-mitigation options)

Frequently Asked Questions about TSCA Reporting of PFAS

Are PFAS regulated under TSCA?

Yes. The USEPA TSCA Section 8(a)(7) Reporting and Recordkeeping Rule for PFAS requires a one-time report by manufacturers or importers of any known or reasonably ascertainable PFAS substances subject to the Rule’s specific reporting criteria. Note that PFAS-related information, following quite different requirements and definitions, is also mandated to be reported separately under the TSCA Chemical Data Reporting program.

What are the reporting requirements for the TSCA Rule?

The Rule applies to manufacturers and importers of PFAS, PFAS in mixtures, and PFAS in articles for commercial purposes from 2011 through 2022.

Required reporting for each covered PFAS are as follows:

  • Trade name, CAS number, chemical identity, and molecular structure
  • Amounts manufactured or imported per year
  • Industrial and consumer detail on categories of use
  • Disposal guidelines
  • Exposure, monitoring, and human and environmental health studies

When is the reporting window for the new PFAS TSCA Rule?

For most companies, the reporting window begins on November 12, 2024, and the deadline for reporting is May 8, 2025. It's important to get started now.

How does the Rule define PFAS?

The Rule applies an expansive structural definition of covered PFAS and perfluorooctanesulfonic acid (PFOS), including 12,697 listed and many more under a broad structural definition.

What is the reportable quantity for PFAS?

There are no de minimis reporting thresholds and very few exemptions.

How can Geosyntec help you address the TSCA Rule?

We can help clients every step of the way and across the globe, from managing due diligence through reporting. Our experts in PFAS chemistry, toxicology, ecotoxicology, program management, and supply-chain management guide clients through this complex process.

How can I get started?

Reach out to our practitioners shown below to learn how we can support TSCA reporting and compliance regarding PFAS.

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