In the wake of recent regulatory adjustments, manufacturers across the United States are reassessing their compliance strategies for toxic substances. One of the most critical developments in 2025 is the TSCA PFAS reporting delay, which affects businesses required to report the use of PFAS (per- and polyfluoroalkyl substances) under the Toxic Substances Control Act. Although the U.S. Environmental Protection Agency (EPA) has extended the deadline, the window to act is narrowing fast.

This delay offers a strategic advantage to forward-thinking compliance teams—but only if they take decisive action now. In this blog, we explore the implications of the TSCA PFAS reporting delay, break down the key requirements of TSCA Section 8(a)(7), and demonstrate how Certivo’s AI-powered compliance platform helps manufacturers stay ahead of the curve.

Understanding the TSCA PFAS Reporting Delay

The EPA’s TSCA PFAS reporting delay, announced in early 2025, pushes back the reporting deadline originally scheduled for late 2024. Under **TSCA Section 8(a)(7)**, manufacturers and importers are required to disclose detailed information about the use, production, and disposal of PFAS dating back to 2011.

While the extension grants more time, it does not lessen the complexity of the TSCA PFAS data submission requirements. Companies must still collect, validate, and submit accurate data for potentially hundreds of products and supply chain partners.

This delay should be viewed as a compliance planning opportunity, not an excuse to slow down. Companies that act now will avoid last-minute scrambles and reduce the risk of enforcement penalties.

What Does TSCA Section 8(a)(7) Require?

TSCA Section 8(a)(7) PFAS reporting extension applies to a wide range of entities, from major chemical manufacturers to small importers. The rule requires the reporting of:

• PFAS identity and volume

• Use and processing of information.

• Worker exposure and disposal methods

• Environmental and health effects

While some small manufacturers have PFAS exemptions, these exemptions are limited and vary depending on the reporting volume and company size. Compliance teams must verify their eligibility and avoid making assumptions that could lead to violations.

Key Compliance Actions for Manufacturers

Regardless of the reporting extension, manufacturers should take proactive steps to ensure full readiness. The PFAS compliance actions manufacturers must take in 2025 include:

1. Inventory and Identify PFAS Usage

Start by conducting a thorough audit of all products, raw materials, and imported goods. Many PFAS chemicals are used in coatings, electronics, textiles, packaging, and industrial applications. Without detailed substance tracking, companies may unintentionally underreport.

2. Map the Supply Chain

Suppliers often hold the key to PFAS data. Engage your upstream partners to provide documentation and disclose any substances of concern. This is where supply chain transparency becomes essential for compliance accuracy.

3. Centralise Documentation

Organise all certificates of analysis, SDSs, and material declarations in one digital location. This will help reduce data gaps and facilitate a prompt response if the EPA requests additional documentation.

4. Invest in PFAS Reporting Software Readiness

Manual reporting methods, such as spreadsheets and email chains, are no longer feasible for large-scale PFAS tracking. Manufacturers must evaluate and adopt PFAS reporting software readiness solutions to manage the volume, detail, and traceability required.

The Market Trend: Digital Compliance Transformation

By 2025, the market is expected to shift rapidly toward digital-first compliance. New U.S. and EU regulations increasingly require product-level traceability, chemical transparency, and data submission in structured digital formats.

This trend aligns closely with the growing demand from investors and consumers for environmental responsibility. Stakeholders want assurance that products are free of hazardous substances, such as PFAS, and that the companies behind them can provide verified compliance data on demand.

Regulatory agencies such as the EPA are also investing in their digital infrastructure, making it likely that future enforcement will rely on automated cross-checking of submitted data. Companies that invest in digital platforms today will be better positioned to comply with and compete in the future.

How Certivo Helps You Navigate TSCA PFAS Compliance

Certivo is explicitly built for forward-looking compliance teams who want to move beyond reactive, manual processes. Here’s how our AI-powered compliance platform supports PFAS reporting and supply chain traceability:

✅ 1. Automated Data Collection

Certivo streamlines the entire data-gathering process. Our platform automates supplier requests, validates documentation, and centralises everything in a single system. This helps with TSCA PFAS data submission requirements while reducing manual error.

✅ 2. Real-Time Compliance Alerts

With our regulatory engine, you stay updated on TSCA PFAS reporting delay adjustments, new EPA mandates, and PFAS substance list changes. We track TSCA Section 8(a)(7) PFAS reporting extension changes so you’re always one step ahead.

✅ 3. Custom Workflows for PFAS Compliance Actions

Certivo lets you customise workflows for **PFAS compliance actions manufacturers** must complete—from initial material screening to final report generation. Our system is scalable, whether you're a multinational producer or evaluating PFAS exemptions for small manufacturers.

✅ 4. Digital-Ready Reporting

When the EPA is ready to collect reports, Certivo ensures your business is too. Our PFAS reporting software readiness includes export-ready formats compatible with EPA portals and future data submission standards.

✅ 5. Supply Chain Collaboration at Scale

Certivo enables you to invite suppliers to collaborate directly within the platform, ensuring accurate and up-to-date declarations for all PFAS-related substances. That’s how we help deliver supply chain transparency at speed and scale.

Small Manufacturers: Why You Shouldn’t Delay

Even with small manufacturer PFAS exemptions, it’s risky to assume you won’t need to report. Many smaller businesses serve as contract manufacturers, private label producers, or parts suppliers, all of which may be required to provide details on PFAS usage.

Certivo simplifies this by guiding smaller teams through every step of the PFAS reporting process, minimising resource strain while ensuring full compliance.

Conclusion: Take Advantage of the TSCA PFAS Reporting Delay

The TSCA PFAS reporting delay is not a pause in regulation — it’s an opportunity to prepare more effectively. With the extension of TSCA Section 8(a)(7), manufacturers must intensify their PFAS compliance actions, upgrade their reporting software, and ensure that their supply chain transparency is digitally enabled.

Certivo gives you everything you need to manage the complexity of PFAS regulations — from automated supplier outreach to AI-driven data validation. Whether you're dealing with TSCA PFAS data submission requirements or simply trying to verify small manufacturer PFAS exemptions, Certivo is your compliance command centre.