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Jul 14, 2025

PFAS Reporting Requirements: Are You Ready for April 2026?

PFAS Reporting Requirements: Are You Ready for April 2026?

PFAS Reporting Requirements: Are You Ready for April 2026?

With growing concerns over environmental pollution and human health, the U.S. Environmental Protection Agency (EPA) is tightening regulations around PFAS (Per- and Polyfluoroalkyl Substances). A key milestone is approaching: the PFAS reporting requirements under the Toxic Substances Control Act (TSCA) are due in April 2026. For manufacturers, importers, and suppliers, this isn’t just another deadline—it’s a legal, operational, and reputational imperative.

Whether you're a small component supplier or a multinational OEM, being PFAS data submission-ready is essential to maintaining compliance, customer trust, and market access. This article breaks down the latest PFAS reporting requirements, what the EPA’s interim final rule means for your business, and how platforms like Certivo can help you stay ahead using AI-powered PFAS compliance software.

Understanding PFAS and Why Compliance Matters

PFAS are a group of over 10,000 synthetic chemicals used in a wide range of industrial and consumer products—from coatings and lubricants to food packaging and fire-fighting foams. Known as "forever chemicals," PFAS do not break down in the environment and are linked to cancer, immune issues, and developmental problems.

To address these risks, the EPA has introduced the PFAS TSCA reporting rule, which requires companies to disclose PFAS usage, manufacturing, or importing activities that occurred at any time since January 1, 2011. The aim is to build a national inventory of PFAS data to inform future restrictions, bans, and cleanup strategies.

PFAS Reporting Requirements: What’s Changing in 2026?

Under the EPA PFAS interim final rule, the new requirements mandate that companies submit detailed information on:

  • Chemical identity

  • Categories of use

  • Volumes manufactured or imported.

  • Byproducts, waste management, and disposal practices

  • Environmental and health effects data

  • Worker exposure and safety controls

The PFAS reporting requirements will apply regardless of quantity or concentration, even in trace amounts within mixtures or articles.

This means even companies that didn’t previously fall under TSCA chemical reporting obligations may now be included.

📅 PFAS TSCA Deadlines

  • Effective Date of Rule: 13 April,2026

  • Final Date for Submission: 13 October,2026

Companies that miss the deadline may face significant penalties and be subjected to audits, product recalls, or restrictions.

PFAS Supply Chain Reporting: A Major Challenge for Businesses

One of the biggest hurdles in meeting PFAS reporting requirements is tracking PFAS supply chains. Many manufacturers may lack complete visibility into their upstream suppliers' use of PFAS, particularly if these substances are incorporated into coatings, additives, or proprietary formulations.

This introduces serious risks:

  • Incomplete or inaccurate disclosures

  • Delayed submission of PFAS data

  • Legal liabilities under the TSCA

  • Loss of contracts with customers requiring complete PFAS transparency

To be PFAS data submission-ready, organisations must implement robust data collection processes and supplier engagement strategies across multiple tiers of their supply chain.

Are Your PFAS Data Submission Ready?

Here’s a quick readiness checklist:

✅ Have you identified all materials and products in your portfolio that potentially contain PFAS?

✅ Have you mapped out your supply chain, including sub-suppliers?

✅ Do you have documented evidence of PFAS use or non-use from suppliers?

✅ Are you tracking changes to the EPA PFAS interim final rule?

✅ Do you have a digital system in place to store and manage PFAS-related data?

If the answer to any of the above is "no," it’s time to take action well before April 2026.

How Certivo Helps You Prepare for PFAS Reporting Requirements

Certivo is an AI-powered compliance platform designed to help manufacturers streamline multi-regulation supply chain compliance, including PFAS, RoHS, and REACH.

Here’s how Certivo helps you meet the PFAS TSCA deadlines:

🔍 1. Automated Supplier Data Collection

Certivo sends out structured, rule-based questionnaires to your supply chain and tracks responses in real-time. This enables PFAS supply chain reporting to be significantly faster and more accurate.

📊 2. PFAS Substance Screening

Upload your Bills of Materials (BOMs), and Certivo automatically screens them against the growing list of regulated PFAS under TSCA, keeping your records up to date.

📑 3. PFAS Documentation Vault

Store all Certificates of Analysis (CoAs), supplier declarations, and compliance statements in a centralised, searchable dashboard.

⚠️ 4. Real-Time Regulatory Monitoring

Certivo continuously monitors updates to PFAS reporting requirements and alerts your compliance team when changes occur in the EPA's PFAS interim final rule or the TSCA database.

📈 5. Compliance Risk Visualisation

Using built-in PFAS compliance software, Certivo generates dashboards to display gaps, risks, and progress toward PFAS data submission readiness.

Market Trends: Why PFAS Compliance Is a Competitive Advantage

Consumers, regulators, and investors are increasingly scrutinising chemical use and product safety. PFAS has become a global hot topic, with action underway in the EU, Canada, and individual U.S. states.

Companies that act early and transparently on PFAS compliance are more likely to:

  • Win contracts with PFAS-free requirements

  • Avoid legal and reputational risks.

  • Be first-to-market with a compliant product.s

  • Build trust with eco-conscious consumers.s

  • Meet ESG and sustainability benchmarks.

By adopting advanced tools like Certivo’s PFAS compliance software, you can turn regulatory pressure into a strategic advantage.

What Happens If You Ignore the 2026 Deadline?

Failing to meet the PFAS TSCA reporting deadline in April 2026 could result in:

  • Civil penalties of up to $50,000 per day

  • Product bans or recalls

  • Loss of access to U.S. government contracts

  • Costly litigation

  • Supply chain disruptions

Given the long reporting look-back period (2011–present), the data-gathering process is extensive. Companies that begin now will have a smoother path to submission.

Next Steps: How to Be PFAS-Compliant by April 2026

✅ Step 1: Start Early

Don’t wait until 2026. Begin supplier outreach and internal assessments now.

✅ Step 2: Centralise Your Data

Use a compliance platform like Certivo to avoid silos and version control issues.

✅ Step 3: Engage Your Supply Chain

Establish clear expectations with all tiers of your suppliers regarding PFAS transparency.

✅ Step 4: Monitor Regulatory Updates

The PFAS list and EPA guidance are continually evolving. Real-time tracking is essential.

✅ Step 5: Train Your Team

Ensure your compliance, procurement, and product development teams understand PFAS reporting requirements and PFAS TSCA deadlines.

Conclusion

PFAS compliance is no longer optional—it’s urgent. With the TSCA PFAS reporting deadline of April 2026 fast approaching, businesses must prepare now to ensure accurate, timely, and complete submissions. The regulatory, operational, and reputational stakes are simply too high.

With the help of Certivo’s AI-powered PFAS compliance software, your organisation can reduce risk, enhance supply chain visibility, and stay ahead of both regulatory and market demands.

Visit Certivo.com to request a demo and start building a brighter, safer, and PFAS-compliant future—before the clock runs out.

Hariprasanth

Hariprasanth is a Chemical Compliance Specialist with nearly four years of experience, underpinned by a degree in Chemical Engineering. He brings in-depth expertise in global product compliance, working across key regulations such as REACH, RoHS, TSCA, Proposition 65, POPs, FMD, and PFCMRT.

Hariprasanth specializes in reviewing technical documentation, validating supplier inputs, and ensuring that products consistently meet regulatory standards. He works closely with cross-functional teams and suppliers to collect accurate material data and deliver clear, audit-ready compliance reports that stand up to scrutiny.

Through his strong analytical skills and regulatory insight, Hariprasanth enables organizations to navigate evolving compliance challenges while aligning with sustainability initiatives in an increasingly dynamic regulatory environment.