There’s a steady rhythm to regulatory news, an update here, a clarification there, but every now and then, something lands that makes compliance leaders sit up straight. The EPA PFAS proposal under TSCA Section 8(a)(7) is one of those moments.

No, it’s not finalized. Not yet. However, the proposal is detailed, far-reaching, and absolutely worth understanding now rather than scrambling to understand it later.

If your business manufactures, imports, processes, or even handles products containing PFAS—even in tiny concentrations—this proposed update could shape your reporting duties for years to come. So consider this a practical walkthrough: what’s being proposed, why it matters, and how companies can prepare without losing months chasing fragmented information.

Why the Proposal Exists: The PFAS Problem Isn’t Going Away

PFAS chemicals—labeled “forever chemicals” thanks to their frightening persistence—have been under a microscope for years. The EPA continues tightening controls, revisiting everything from drinking-water standards to industrial discharge limits. This latest step, the EPA PFAS proposal, is not an isolated move; it’s part of a wider national strategy.

The agency wants deeper visibility into the life cycle of PFAS across U.S. commerce. And the way to achieve that visibility, according to the proposal, is to expand PFAS data collection from industries most closely tied to production and import activities.

This is where TSCA PFAS reporting comes into the picture. And it’s only getting more complex.

A Quick Refresher on TSCA Section 8(a)(7)

If you didn’t follow the original rule rollout, here’s a simple recap. TSCA Section 8(a)(7) mandates that companies submit detailed PFAS use and exposure information to the EPA—historical, not just current. It compelled organizations to review years of procurement, supply chain, and product development records.

The proposed update aims to “streamline” some requirements but also expand clarity and tighten definitions. It’s a mixed bag: some burdens lighten, others grow.

Regardless, you should expect PFAS reporting requirements to become more data-intensive, not less.

What the EPA’s Proposal Actually Changes

While the proposal is still open for comments and could shift, several themes appear repeatedly. These are the parts compliance managers should pay attention to.

1. Clearer Definitions of PFAS Categories

Instead of the extremely broad structural definition used earlier, the EPA PFAS proposal introduces refined categories, helping companies determine more easily whether a substance counts as PFAS. In theory, this reduces unnecessary reporting. In practice, it may require revisiting chemical inventory records.

This sharper categorization also improves PFAS data collection, giving the agency more usable information instead of thousands of ambiguous submissions.

2. Adjusted Reporting Burden for Small Manufacturers

One of the major complaints about the original rule was the heavy compliance burden placed on small manufacturers. The proposed update attempts to address that, potentially limiting full reporting requirements for very small entities—though not exempting them entirely.

However, here’s the catch: companies will need the right internal documentation systems to demonstrate their qualification for exemptions. If you don’t already have a chemical recordkeeping system in place, this is the moment to start.

3. More Flexible Historical Record Expectations

Under the original rule, companies had to dig through decades of data. Many organizations publicly stated that retrieving 30 years of PFAS information was nearly impossible. The TSCA PFAS reporting update may allow alternative data sources, reasonable assumptions, or partial records if full details no longer exist.

That doesn’t mean “easy,” just “more realistic.”

4. Expanded Product Categories Likely to be Affected

From industrial coatings to semiconductor fabrication materials to consumer goods with water-resistance features—more sectors may find themselves pulled into the reporting net.

If a company has dismissed PFAS concerns in the past because the material was only a small additive or part of a coated component, this is the time for a re-evaluation. Several industries may need to implement structured PFAS data collection processes for the first time.

Why Businesses Should Treat This Proposal Seriously—Even If It’s Not Final

Proposed rules have a funny way of becoming tomorrow’s compliance scramble. And PFAS oversight isn’t loosening; if anything, the momentum is accelerating.

Here’s the wide-angle view:

• States are aggressively regulating PFAS in packaging, textiles, consumer goods, and more.

• The EPA is moving forward with drinking-water MCLs and disposal/release guidelines.

• Retailers increasingly require PFAS declarations from suppliers.

The proposed PFAS reporting requirements under TSCA Section 8(a)(7) won’t exist in a vacuum. If anything, they’ll become a foundation for broader enforcement actions, product redesign efforts, and supply chain transparency programs.

Businesses preparing now won’t be stuck with last-minute reengineering or panicked data hunts.

Practical Steps Companies Should Take Now (Even Before Finalization)

You don’t need to overhaul your compliance system yet, but you should build early habits. These actions are simple and manageable, and they’ll position your team ahead of upcoming requirements.

1. Map Where PFAS Show Up in Your Business

Most companies underestimate the number of products that contain PFAS. They show up in:

• coatings

• adhesives

• gaskets

• lubricants

• wires

• electronics

• membranes

• protective layers

Do a preliminary mapping exercise. Even a high-level inventory reduces risk and prepares you for potential TSCA PFAS reporting.

2. Engage Your Suppliers—Now

PFAS information rarely lives within your four walls. It sits with raw material suppliers, custom compounders, contract manufacturers, and specialty chemical distributors.

Start requesting updated PFAS statements immediately. You don't need final forms yet—simple declarations or ingredient summaries help build your PFAS data collection backbone.

For a structured approach, you can reference Certivo’s guide on supplier compliance.

3. Centralize Chemical Data Before the Rule Finalizes

The easiest way to lose months on PFAS reporting is to scatter your information across spreadsheets, emails, and PDFs. If you already maintain a chemical inventory tool, review how well it tracks historical PFAS data.

If you don’t, Certivo’s digital chemical tracking tools are a good place to start. Even a lightweight system helps you prepare for changing PFAS reporting requirements.

4. Assign Internal Owners for Each PFAS Data Category

Under the proposal, companies may need to assemble information on:

• chemical identities

• categories

• historical uses

• exposure potential

• byproducts

• disposal practices

• volume estimates

Assigning ownership early prevents the last-minute “Who has this file?” panic that plagues many TSCA submissions.

Certivo’s step-by-step PFAS readiness checklist can help structure internal roles.

5. Stay Informed—PFAS Rules Shift Often

This cannot be overstated: PFAS policy is evolving rapidly. The finalized version of the EPA PFAS proposal may differ from what’s currently outlined. Subtle language tweaks can trigger major implications for compliance teams.

Set up regulatory alerts or subscribe to EPA update notifications. Don’t wait for finalization; anticipate it.

What If Your Company Has Never Tracked PFAS Before?

You’re not alone. Many small and medium-sized manufacturers never imagined they’d need a PFAS reporting workflow. Some assumed only chemical producers would be affected. But PFAS are sneaky—they’re in surfactants, coatings, waterproofing materials, and so many industrial intermediates.

Start simple:

• Identify PFAS-suspect materials.

• Build an email template for supplier inquiries.

• Store supplier statements in one shared location.

• Prioritize high-volume or high-risk materials.

Getting this early structure in place dramatically lightens the load if the proposed TSCA Section 8(a)(7) changes move forward.

So What’s Next?

Ultimately, the EPA PFAS proposal is a signal—clear, direct, and impossible to ignore. Businesses are expected to increase their transparency, tighten their chemical documentation, and establish robust reporting habits.

You don’t need to overhaul your compliance systems yet. But beginning the groundwork now gives your organization breathing room when regulations eventually solidify.

Because they will solidify. And when that happens, the companies that already understand their PFAS footprint will be in far better shape than those scrambling through email archives and decade-old purchase orders.

PFAS isn’t a temporary compliance topic—it’s the next long-term regulatory landscape. Companies that start preparing today will face fewer surprises tomorrow.