The U.S. Environmental Protection Agency has established a critical federal PFAS reporting requirement under TSCA Section 8(a)(7), and manufacturers and importers face a rapidly approaching compliance deadline beginning April 13, 2026. This one-time retrospective reporting rule requires organizations to disclose detailed information about PFAS manufactured or imported since January 1, 2011, creating immediate compliance obligations for companies across industries that have manufactured, processed, imported, or distributed PFAS-containing products over the past 15 years.

For compliance leaders, regulatory teams, and executive decision-makers, understanding PFAS TSCA 8(a)(7) reporting requirements is essential to avoiding enforcement actions, meeting federal deadlines, and demonstrating environmental stewardship. The regulation applies broadly across sectors—from electronics and automotive to textiles, cosmetics, and industrial chemicals—requiring organizations to assemble historical production data, supplier information, and use case documentation that most companies do not maintain in readily accessible formats.

This comprehensive guide explains what PFAS TSCA 8(a)(7) reporting entails, who must comply, critical reporting deadlines and data requirements, and how manufacturers can prepare for the October 13, 2026 deadline while implementing AI-powered compliance infrastructure that scales beyond this one-time requirement to support ongoing PFAS regulatory obligations.

Table of Contents

1. What Is PFAS TSCA Section 8(a)(7)?

2. What Changed and Why EPA Is Requiring PFAS Reporting Now

3. Who Must Comply: Industry-by-Industry Breakdown

4. TSCA 8(a)(7) Reporting Scope and Data Requirements

5. Key Reporting Deadlines and Timeline

6. Business Risks, Penalties, and Executive-Level Impact

7. PFAS TSCA 8(a)(7) Compliance Action Checklist

8. How Certivo Simplifies PFAS TSCA 8(a)(7) Reporting

1. What Is PFAS TSCA Section 8(a)(7)?

TSCA Section 8(a)(7) authorizes the Environmental Protection Agency to require reporting and recordkeeping for specific chemical substances when EPA determines such information is necessary for effective administration of the Toxic Substances Control Act. The agency invoked this authority to establish comprehensive PFAS reporting requirements announced on May 13, 2025.

Legislative Authority and Regulatory Objectives

The PFAS TSCA 8(a)(7) reporting rule represents the federal government's most comprehensive effort to understand the full scope of PFAS manufacturing, importation, use, and distribution across the U.S. economy. EPA's stated objectives include:

• Improving oversight of PFAS production and importation volumes

• Understanding exposure pathways through product use categories and applications

• Assessing environmental impacts from PFAS releases and disposal

• Informing future regulation of specific PFAS substances or use categories

• Supporting risk assessments for PFAS health and environmental effects

This information-gathering exercise establishes the factual foundation for potential future PFAS restrictions, use limitations, or phase-out requirements under TSCA or other environmental statutes.

One-Time Retrospective Reporting

Unlike ongoing annual reporting requirements under programs like TSCA Section 8(e) or Toxics Release Inventory, PFAS TSCA 8(a)(7) reporting is a one-time retrospective exercise covering a 15-year historical period from January 1, 2011 through the reporting deadline.

Organizations must compile and report data spanning this entire period, creating significant data assembly challenges for companies that may have experienced:

• Changes in product portfolios

• Mergers, acquisitions, or divestitures

• Supplier transitions

• Manufacturing process modifications

• Recordkeeping system migrations

The retrospective nature means organizations cannot simply report current operations—they must reconstruct historical PFAS activities across a decade and a half of business operations.

Reporting Standard: Known or Reasonably Ascertainable

PFAS TSCA 8(a)(7) reporting applies to information that is "known or reasonably ascertainable" to the reporting entity. This standard means:

Known Information - Data already in the organization's possession, including:

• Manufacturing records

• Import documentation

• Sales data

• Product formulation specifications

• Supplier declarations

Reasonably Ascertainable Information - Data the organization can obtain through reasonable inquiry without extraordinary effort, such as:

• Information available from suppliers through standard requests

• Data accessible from business records with reasonable effort

• Information derivable from existing documentation

Organizations cannot claim ignorance of PFAS presence simply because they have not previously tracked these substances systematically. The "reasonably ascertainable" standard requires due diligence in gathering available information even when it demands significant effort.

Understanding TSCA compliance frameworks helps organizations interpret EPA's reporting expectations and implement appropriate data collection strategies.

Official regulatory source (EPA): https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/tsca-section-8a7-reporting-and-recordkeeping

2. What Changed and Why EPA Is Requiring PFAS Reporting Now

The PFAS Information Gap

Despite decades of PFAS use across industries, EPA lacked comprehensive data regarding:

• Total volume of PFAS manufactured and imported into the United States

• Specific PFAS substances in commercial use

• Product categories and applications where PFAS appears

• Geographic distribution of PFAS manufacturing and processing

• Worker exposure scenarios across industries

• Environmental release pathways and disposal practices

This information gap prevented EPA from conducting thorough risk assessments, prioritizing regulatory action, or understanding the full scope of potential PFAS exposure affecting human health and the environment.

Regulatory Context and Congressional Pressure

PFAS TSCA 8(a)(7) reporting follows increasing congressional and public pressure for federal PFAS action. The reporting rule enables EPA to:

• Respond to Congressional mandates for comprehensive PFAS information

• Support state-level regulation by providing manufacturers data states can use in their own PFAS programs

• Inform international coordination with OECD countries implementing PFAS restrictions

• Establish baseline data for measuring progress on PFAS reduction initiatives

Why Reporting Opens in April 2026

EPA established the April 13, 2026 reporting opening date to provide organizations with approximately one year from the May 2025 regulatory announcement to prepare for compliance. This timeline recognizes the significant data assembly burden while creating urgency for manufacturers to begin compliance activities immediately.

Organizations that defer PFAS TSCA 8(a)(7) reporting preparation until early 2026 will face severe time pressure to meet the October 13, 2026 deadline given the complexity of gathering 15 years of historical data across multi-tier supply chains.

3. Who Must Comply: Industry-by-Industry Breakdown

PFAS TSCA 8(a)(7) reporting obligations extend across industries that manufacture, import, or process PFAS substances or PFAS-containing articles:

PFAS Manufacturers

Organizations that manufacture PFAS substances in the United States must report comprehensive production data. Manufacturing includes:

• Chemical synthesis of PFAS compounds

• Processing of PFAS into intermediate forms

• Formulation of PFAS-containing mixtures

• Incorporation of PFAS into products during manufacturing

Manufacturers face the most extensive reporting obligations, including detailed chemical identity, production volume, use categories, and environmental release data.

PFAS Importers

Importers bring PFAS substances or PFAS-containing articles into U.S. commerce. Importation triggering reporting includes:

• Bulk PFAS chemical imports

• PFAS-containing raw materials and intermediates

• Articles containing PFAS (subject to specific thresholds and criteria)

• Products where PFAS serves functional purposes

Importers share reporting responsibility even when they do not manufacture PFAS, creating compliance obligations for organizations throughout import supply chains.

Importers of PFAS-Containing Articles

Certain importers of articles containing PFAS must report when:

• PFAS is intentionally present in the article

• PFAS serves a functional purpose in the article

• Import volumes exceed specified thresholds

This provision captures organizations importing finished goods or components where PFAS provides performance characteristics but the importer may not have previously considered themselves "PFAS importers."

Industry Sectors Significantly Affected

Electronics and Electrical Equipment

PFAS appears in electronics manufacturing including:

• Circuit board coatings and laminates

• Cable and wire insulation

• Semiconductor processing chemicals

• Display technologies

Automotive and Transportation

Automotive sector PFAS uses include:

• Brake fluids and hydraulic systems

• Fuel system components

• Interior fabric treatments

• Weatherstripping and seals

Textiles, Apparel, and Footwear

Textile applications encompass:

• Water-resistant and stain-resistant treatments

• Outdoor and performance apparel

• Footwear materials and coatings

• Upholstery fabrics

Medical Devices and Healthcare

Medical device manufacturers use PFAS in:

• Surgical gowns and drapes

• Medical tubing and catheters

• Implantable devices

• Pharmaceutical packaging

Cosmetics and Personal Care

Cosmetics sector PFAS applications include:

• Long-wear makeup formulations

• Sunscreens and moisturizers

• Hair care treatments

• Dental products

Food Packaging and Food Contact Materials

Food packaging uses include:

• Grease-resistant paper and cardboard

• Non-stick coatings

• Take-out containers

• Microwave popcorn bags

Construction and Building Materials

Construction materials containing PFAS:

• Weatherproofing membranes

• Paints and coatings

• Sealants and adhesives

• Roofing materials

Consumer Goods and Household Products

Broad consumer categories affected:

• Non-stick cookware

• Cleaning products

• Carpet treatments

• Furniture fabrics

Chemicals and Plastics

Chemical manufacturers producing or using PFAS as:

• Processing aids

• Surfactants

• Polymer additives

• Industrial chemicals

Industrial and Commercial Products

Industrial applications spanning:

• Lubricants and hydraulic fluids

• Industrial coatings

• Fire suppression systems

• Metal plating processes

The breadth of affected industries demonstrates that PFAS TSCA 8(a)(7) reporting extends far beyond traditional chemical manufacturing to encompass virtually any sector that has manufactured, imported, or used PFAS over the past 15 years.

4. TSCA 8(a)(7) Reporting Scope and Data Requirements

PFAS TSCA 8(a)(7) reporting requires detailed disclosure across multiple data categories:

Chemical Identity Information

PFAS Substance Identification:

• Chemical name and CAS Registry Number

• Chemical structure and molecular formula

• Trade names and synonyms

• Categories and subcategories of PFAS

Organizations must identify specific PFAS substances manufactured or imported, not simply report "PFAS present." This requires chemical-level substance tracking and supplier data regarding exact PFAS identity.

Manufacturing and Import Volume

Production Quantities:

• Annual production volume for each PFAS substance

• Historical volumes covering the reporting period (2011-present)

• Volume ranges if exact quantities constitute confidential business information

Import Quantities:

• Annual import volumes for PFAS substances

• Article import volumes when PFAS-containing articles trigger reporting

• Country of origin for imported PFAS

Volume data enables EPA to understand the scale of PFAS commerce and prioritize substances with highest production or import levels.

Use Categories and Applications

Product and Process Uses:

• Industrial use categories where PFAS is employed

• Consumer and commercial product categories

• Manufacturing process applications

• Function PFAS serves in each use category

EPA seeks to understand why PFAS is used across applications, informing assessments of essential vs. non-essential uses that may be targeted for restriction.

Processing and Distribution Information

Commercial Activities:

• Processing operations involving PFAS

• Distribution channels and customer types

• Geographic locations of manufacturing and processing facilities

• Number of workers potentially exposed

This information helps EPA assess exposure pathways and geographic distribution of PFAS activities.

Environmental Release and Disposal

Release Data:

• Releases to air, water, and land

• Waste management practices

• Disposal methods for PFAS-containing waste

• Recycling or reuse programs

Environmental release information supports EPA's understanding of PFAS contamination sources and pathways into drinking water, soil, and ecosystems.

Exposure Information

Worker and Consumer Exposure:

• Number of workers exposed during manufacturing or processing

• Consumer exposure scenarios through product use

• Protective equipment and exposure controls

• Known or potential health effects

Exposure data informs EPA risk assessments and prioritization of substances or uses presenting greatest health concerns.

Data Assembly Challenges

Compiling PFAS TSCA 8(a)(7) reporting data presents significant challenges:

Historical Recordkeeping Limitations - Organizations may lack complete records spanning 2011-present due to recordkeeping retention policies, system migrations, or business changes.

Supplier Data Dependency - Importers and downstream users depend on supplier information regarding PFAS identity and quantities, requiring extensive supplier engagement to obtain supplier declarations and certifications.

Product Portfolio Complexity - Companies with thousands of products or formulations must assess PFAS presence across entire portfolios, potentially requiring testing where supplier data is unavailable.

Multi-Site Coordination - Organizations operating multiple manufacturing facilities must consolidate data across sites, business units, and geographic regions.

Organizations lacking centralized substance data management systems face severe challenges assembling accurate, complete PFAS TSCA 8(a)(7) reports from fragmented spreadsheets, email archives, and disconnected databases.

5. Key Reporting Deadlines and Timeline

PFAS TSCA 8(a)(7) reporting follows a phased deadline structure based on organization size:

Understanding the April 13, 2026 Reporting Opening

The reporting opening date marks when EPA's Central Data Exchange system becomes available for PFAS TSCA 8(a)(7) submissions. Organizations should:

• Complete data assembly before April 2026

• Allocate time for CDX system familiarization and testing

• Submit reports early to address any technical or data quality issues

• Avoid last-minute submissions approaching the October deadline

The Critical October 13, 2026 Deadline

October 13, 2026 represents the compliance deadline for most organizations. The six-month window between reporting opening and this deadline is deceptively short given the data assembly complexity. Organizations should:

Begin Immediately (Q1-Q2 2026):

• Inventory products and processes potentially involving PFAS

• Engage suppliers for PFAS declarations

• Assess historical recordkeeping and identify data gaps

• Assign cross-functional resources to compliance project

Data Assembly Phase (Q2-Q3 2026):

• Compile chemical identity and volume data

• Document use categories and applications

• Gather environmental release information

• Validate data accuracy and completeness

Report Preparation (Q3 2026):

• Prepare CDX submissions

• Conduct quality control reviews

• Resolve confidential business information claims

• Obtain management approvals

Submission (Q3-Q4 2026):

• Submit reports through CDX

• Retain supporting documentation

• Address EPA follow-up inquiries

Organizations starting preparation in Q3 2026 or later will struggle to meet the October deadline without automated compliance workflows accelerating data collection and validation.

Small Manufacturer Extended Deadline

Small manufacturers meeting EPA's production volume threshold receive an extended deadline of April 13, 2027. This six-month extension recognizes resource constraints facing smaller organizations while maintaining the federal government's information-gathering objectives.

Small manufacturers should not defer preparation activities until late 2026—the data assembly burden remains substantial regardless of organization size.

6. Business Risks, Penalties, and Executive-Level Impact

PFAS TSCA 8(a)(7) reporting failures create significant business risks:

Federal Enforcement and Penalties

EPA enforces TSCA reporting requirements with authority including:

• Civil penalties for failure to report

• Additional penalties for false or misleading information

• Enforcement orders requiring compliance

• Criminal prosecution for knowing violations

TSCA civil penalties can reach tens of thousands of dollars per day of violation, creating substantial financial exposure for organizations missing reporting deadlines or submitting incomplete reports.

Regulatory Scrutiny and Follow-Up

Organizations submitting incomplete, inconsistent, or questionable PFAS TSCA 8(a)(7) reports face:

• EPA follow-up inquiries demanding clarification

• Requests for supporting documentation

• Potential compliance audits

• Enhanced scrutiny of future TSCA submissions

Regulatory attention consumes compliance resources and creates ongoing administrative burdens beyond initial reporting.

Supply Chain and Market Access Implications

PFAS TSCA 8(a)(7) reporting creates transparency regarding organizational PFAS use that affects:

Customer Requirements - Enterprise customers may request copies of PFAS reports or demand commitments to PFAS phase-out based on reported data.

Investor Scrutiny - ESG-focused investors may evaluate reported PFAS volumes and uses as environmental risk factors affecting valuations.

Public Disclosure - EPA may publish aggregated or facility-specific PFAS data, creating public transparency about organizational PFAS activities.

Competitive Intelligence - Competitors and advocacy organizations may analyze reported data to understand industry PFAS use patterns.

Strategic Planning Implications

PFAS TSCA 8(a)(7) reporting data will inform EPA's future regulatory agenda. Organizations should anticipate that:

• High-volume PFAS substances may face prioritized risk assessments

• Uses deemed non-essential may be targeted for restriction

• Industries reporting significant PFAS use may face sector-specific regulations

• Geographic concentrations of PFAS manufacturing may trigger regional initiatives

Accurate reporting enables organizations to participate constructively in future regulatory development based on factual understanding of PFAS commerce rather than speculation.

Executive Fiduciary Considerations

Board members and executive officers bear responsibility for environmental compliance. PFAS TSCA 8(a)(7) reporting failures resulting in enforcement actions, market disruption, or reputational damage create potential fiduciary concerns where adequate compliance systems were not implemented.

7. PFAS TSCA 8(a)(7) Compliance Action Checklist

Organizations subject to PFAS TSCA 8(a)(7) reporting should implement these actions immediately:

☑ Determine Reporting Obligation

Assess Organizational Activities:

• Identify whether organization manufactured PFAS since 2011

• Determine if organization imported PFAS substances or PFAS-containing articles

• Evaluate whether processing activities trigger reporting

• Clarify reporting entity for multi-facility or restructured organizations

Understand Applicability Criteria:

• Review EPA guidance on reporting thresholds and exemptions

• Determine if small manufacturer extended deadline applies

• Identify covered vs. exempt PFAS substances

• Assess article import applicability

☑ Inventory Potentially Affected Products and Processes

Conduct PFAS Use Assessment:

• Review product formulations for PFAS-containing ingredients

• Evaluate manufacturing processes using PFAS as processing aids

• Identify imported materials potentially containing PFAS

• Prioritize high-volume or high-risk products for detailed assessment

Document Historical Changes:

• Track product portfolio evolution since 2011

• Identify discontinued products that may require reporting

• Account for acquired or divested business units

• Address facility closures or relocations

☑ Engage Suppliers for PFAS Information

Launch Supplier Data Collection:

• Develop standardized PFAS information requests aligned with TSCA requirements

• Distribute requests to chemical suppliers, raw material vendors, and component manufacturers

• Establish response deadlines allowing validation time before reporting deadline

• Implement systematic supplier engagement workflows

Validate Supplier Responses:

• Verify chemical identity information accuracy

• Confirm volume and concentration data

• Request supporting documentation for significant PFAS quantities

• Address incomplete or inconsistent supplier responses

☑ Compile Historical Production and Import Data

Assemble Volume Information:

• Extract production volumes from manufacturing records

• Compile import data from customs documentation and purchase records

• Reconstruct historical volumes where current systems lack data

• Aggregate volumes across facilities and time periods

Document Use Categories:

• Classify PFAS uses according to EPA categories

• Describe functional purposes PFAS serves in applications

• Identify end-use products and industries

• Map PFAS through product value chains

☑ Gather Environmental Release and Exposure Data

Compile Release Information:

• Review environmental monitoring data

• Extract waste management records

• Document disposal practices

• Identify PFAS releases to air, water, and land

Assess Worker Exposure:

• Count workers potentially exposed during manufacturing or processing

• Document exposure controls and protective equipment

• Review occupational health records where available

• Describe consumer exposure scenarios

☑ Prepare EPA Central Data Exchange (CDX) Submission

Register for CDX Access:

• Establish CDX accounts for reporting personnel

• Obtain necessary system authorizations

• Familiarize team with CDX reporting interface

• Test data entry and submission processes

Organize Reporting Data:

• Structure data according to EPA reporting format

• Prepare confidential business information claims

• Conduct quality control reviews

• Obtain management approvals

☑ Submit Reports and Maintain Documentation

Complete Submissions:

• Submit PFAS TSCA 8(a)(7) reports through CDX before October 13, 2026 deadline

• Retain confirmation of successful submission

• Prepare for potential EPA follow-up inquiries

Preserve Supporting Records:

• Maintain supplier declarations and certifications

• Retain production and import documentation

• Preserve environmental monitoring and waste records

• Organize files enabling rapid response to EPA requests

Organizations implementing centralized PFAS data management transform TSCA reporting from crisis-driven projects to systematic capabilities supporting ongoing regulatory obligations.

☑ Monitor Regulatory Developments

Track EPA Guidance Updates:

• Monitor EPA TSCA website for reporting clarifications

• Participate in industry association information-sharing

• Engage regulatory consultants for interpretation support

• Assess potential future PFAS restrictions informed by reporting data

Organizations maintaining continuous regulatory intelligence anticipate EPA's post-reporting regulatory agenda.

8. How Certivo Simplifies PFAS TSCA 8(a)(7) Reporting

Certivo provides manufacturers and importers with an AI-powered compliance management platform specifically designed for PFAS TSCA 8(a)(7) reporting and broader PFAS regulatory obligations:

AI-Driven PFAS Identification and Tracking

Certivo creates comprehensive visibility into PFAS presence across products, materials, and supply chains:

• Substance-level PFAS tracking linking chemical identity to products and formulations

• Bill of materials integration mapping PFAS through components and assemblies

• Supplier declaration consolidation organizing PFAS certifications by supplier and material

• Historical data reconstruction assembling 15-year retrospective view from available records

Organizations achieve the chemical-level PFAS intelligence required for accurate TSCA reporting without manual data archaeology.

Automated Data Collection for Reasonably Ascertainable Information

Certivo automates the supplier engagement and data assembly required for "reasonably ascertainable" compliance:

• Standardized information requests aligned with TSCA reporting requirements

• Automated supplier workflows distributing requests and tracking responses

• Validation rules ensuring supplier data includes required elements

• Gap identification flagging missing or incomplete information requiring follow-up

The platform scales supplier data collection across hundreds of suppliers without manual tracking creating bottlenecks.

TSCA Reporting Readiness and CDX Preparation

Certivo streamlines TSCA report preparation:

• Reporting data compilation assembling required elements from centralized databases

• Volume aggregation calculating production and import quantities across time periods

• Use category classification mapping PFAS applications to EPA taxonomies

• Quality control validation identifying data inconsistencies before submission

Organizations generate TSCA-compliant reports from structured data rather than manually assembling submissions from fragmented sources.

Multi-Industry and Multi-Framework Visibility

Certivo provides unified compliance visibility across TSCA and other PFAS regulations:

• Jurisdiction-specific tracking showing compliance status for TSCA and state PFAS requirements

• Cross-regulatory data reuse leveraging TSCA data for other reporting obligations

• Comparative analysis identifying products subject to multiple PFAS requirements

• Expansion readiness supporting future PFAS regulatory responses

Organizations investing in TSCA reporting build scalable infrastructure supporting evolving PFAS compliance landscape.

Regulatory Intelligence and Alert Systems

Certivo's AI continuously monitors PFAS regulatory developments:

• EPA guidance tracking monitoring TSCA reporting clarifications and updates

• Enforcement precedent analysis identifying compliance trends and agency priorities

• Future regulation assessment tracking potential post-reporting PFAS restrictions

• Deadline management ensuring timely compliance with October 2026 deadline

The platform eliminates manual regulatory monitoring that creates awareness gaps.

Audit-Ready Documentation Management

Certivo organizes compliance evidence supporting TSCA reports:

• Supplier certification repositories maintaining current PFAS declarations

• Production records integration linking volume data to reporting submissions

• Environmental data compilation organizing release and disposal information

• Compliance history tracking demonstrating due diligence for EPA inquiries

Organizations respond to EPA follow-up requests with complete, organized documentation rather than scrambling to assemble evidence retroactively.

Cross-Functional Collaboration and Workflow Automation

Certivo connects teams across compliance, manufacturing, procurement, and environmental functions:

• Role-based access providing relevant TSCA data to each stakeholder

• Workflow automation routing data collection tasks to appropriate teams

• Notification systems alerting teams to deadline-driven actions

• Executive dashboards giving leadership visibility into reporting readiness

The platform transforms PFAS TSCA 8(a)(7) reporting from isolated compliance projects to coordinated, enterprise-wide capabilities.

Conclusion

PFAS TSCA Section 8(a)(7) reporting represents the most comprehensive federal PFAS information-gathering exercise in U.S. history, requiring manufacturers and importers to disclose detailed data about PFAS manufactured or imported since 2011. With reporting opening April 13, 2026 and the primary deadline of October 13, 2026 rapidly approaching, organizations face compressed timelines to assemble 15 years of historical production, import, use, and environmental release data.

The retrospective nature of this requirement, combined with the "reasonably ascertainable" information standard, creates significant compliance challenges for organizations lacking systematic PFAS tracking. Companies that defer preparation activities until mid-2026 will struggle to meet federal deadlines without automated compliance infrastructure accelerating data collection, supplier engagement, and report preparation.

Beyond this one-time reporting requirement, the data submitted to EPA will inform future PFAS regulatory priorities, potential restrictions, and risk assessments. Organizations investing in PFAS TSCA 8(a)(7) compliance build scalable capabilities supporting the evolving federal and state PFAS regulatory landscape while demonstrating environmental stewardship to customers, investors, and regulators.

The question is not whether your organization will achieve PFAS TSCA 8(a)(7) reporting compliance by October 2026. The question is whether you will build the PFAS data management infrastructure required for continuous regulatory readiness as federal and state PFAS requirements expand beyond this initial reporting exercise.

Ready to transform your PFAS TSCA 8(a)(7) reporting approach? Contact Certivo to see how AI-powered compliance automation helps organizations meet the October 2026 federal deadline while building scalable PFAS regulatory infrastructure.