# PFAS Reporting 2026 - Complete Site Content > This document contains the complete content of pfasreporting2026.com in markdown format for AI systems. Last updated: January 2025. --- # Overview PFAS Reporting 2026 is the definitive resource for US importers and manufacturers navigating EPA's TSCA 8(a)(7) PFAS reporting requirements. The deadline is **May 8, 2026**, covering all PFAS manufactured or imported between January 1, 2011 and December 31, 2022. ## Key Compliance Facts - **Final Deadline**: May 8, 2026 - **Lookback Period**: January 1, 2011 through December 31, 2022 - **Maximum Penalty**: Up to $50,000 per day per violation - **No Small Business Exemption**: Companies of all sizes must report - **No Article Exemption**: Importers of finished goods containing PFAS must report - **No De Minimis Threshold**: Even small quantities trigger reporting --- # Compliance Guides ## What is PFAS? ### Introduction PFAS (per- and polyfluoroalkyl substances) are a class of thousands of synthetic chemicals characterized by strong carbon-fluorine bonds. Under EPA's TSCA 8(a)(7) rule, any substance containing at least one fully fluorinated carbon atom is considered a PFAS for reporting purposes. ### Structural Definition The EPA defines PFAS as any chemical structure containing at least one of these substructures: - R-CF2-CF3 (perfluorinated carbon chain) - R-CF2-CF2- (internal perfluorinated carbons) - CF3-CF2- (perfluorinated methyl group attached to perfluorinated carbon) This structural definition captures over 10,000 known PFAS compounds and potentially many more. ### Common Properties - Extremely stable and persistent in the environment - Resistant to heat, water, oil, and grease - Do not break down naturally (hence "forever chemicals") - Bioaccumulate in living organisms - Used for their water and stain-repellent properties ### Where PFAS Are Found PFAS appear in countless consumer and industrial products: - Non-stick cookware (Teflon) - Water-resistant clothing and textiles - Stain-resistant carpets and upholstery - Food packaging (grease-resistant containers) - Firefighting foams (AFFF) - Electronics and semiconductors - Automotive components - Medical devices - Cosmetics and personal care products - Industrial lubricants and coatings --- ## Filing Deadline: May 8, 2026 ### Timeline - **Rule Published**: October 11, 2023 - **Original Deadline**: November 13, 2025 - **Extended Deadline**: May 8, 2026 - **Lookback Start**: January 1, 2011 - **Lookback End**: December 31, 2022 ### Why the Extension? EPA granted a 180-day extension recognizing the complexity of: - Gathering historical data spanning 12+ years - Obtaining information from foreign suppliers - Identifying PFAS in imported articles - The sheer volume of affected entities ### No Further Extensions Expected EPA has indicated this will be the final deadline. Companies should not expect additional relief and should begin compliance activities immediately. ### What Must Be Reported For each PFAS manufactured or imported, you must report: - Chemical identity (CAS number, name, structure) - Production volumes by year - Categories of use - Byproducts from manufacturing - Environmental and health effects data - Worker exposure information - Disposal methods --- ## Penalties and Fines ### Civil Penalties TSCA violations can result in civil penalties of up to **$50,000 per day per violation**. The penalty amount is adjusted annually for inflation. ### How Penalties Accumulate - Each unreported PFAS = potential separate violation - Each day of non-compliance = separate violation - Multiple products × multiple chemicals × multiple days = massive potential exposure ### Example Calculation A company that: - Imports 10 products containing PFAS - Each product has 3 PFAS chemicals - Fails to report for 100 days after deadline Could face: 10 × 3 × 100 × $50,000 = **$150 million** in potential penalties ### Criminal Penalties Knowing or willful violations can result in: - Criminal fines - Imprisonment up to one year - Felony charges for repeat offenders ### Penalty Mitigation Factors EPA considers: - Nature and extent of violation - Economic benefit gained from non-compliance - Company size and ability to pay - Compliance history - Good faith efforts to comply - Cooperation with enforcement ### Best Protection Timely, good-faith compliance—even imperfect—significantly reduces penalty exposure. --- ## Article Importer Exemption (Why You Don't Qualify) ### The Myth Many importers believe the "article exemption" protects them from PFAS reporting. This is incorrect. ### The Reality TSCA 8(a)(7) explicitly states there is **no article exemption** for PFAS reporting. This was a deliberate policy choice by EPA. ### What "Article Importer" Means An article importer is any company that imports finished goods into the United States. Under this rule, if those goods contain PFAS substances—even as coatings or surface treatments—the importer has reporting obligations. ### Common Misconceptions - "I only import finished products" → You must still report - "I don't manufacture anything" → Importing = manufacturing under TSCA - "My products are consumer goods" → Consumer products are fully covered - "PFAS is just a coating" → Surface treatments trigger reporting ### Who Must Report Any entity that at any point between 2011-2022: - Manufactured PFAS domestically - Imported PFAS chemicals - Imported products/articles containing PFAS ### The Implication Thousands of companies that have never considered themselves chemical manufacturers now have EPA reporting obligations. --- ## Supplier Letter Template ### Why You Need This As an importer, you don't directly know the PFAS content of products you bring into the US. That information resides with your foreign suppliers. ### The Problem Suppliers are not automatically obligated to provide PFAS data. Many will not voluntarily share proprietary formulation information. ### The Solution A formal Supplier Demand Letter puts suppliers on notice and creates documentation of your good-faith compliance efforts. ### Key Elements to Include 1. **Specific request for PFAS information** - CAS numbers for all PFAS in products - PFAS concentrations - Function of PFAS in the product 2. **Reference to legal requirement** - Cite TSCA Section 8(a)(7) - Explain your reporting obligations - Note the deadline 3. **Deadline for response** - Give specific date (at least 30 days) - State consequences of non-response 4. **Format requirements** - Request data in specific format - Ask for signed attestation 5. **Documentation of request** - Keep copies of all correspondence - Document delivery method - Track response status ### If Suppliers Don't Respond - Document all attempts - Consider product testing - Use reasonable estimates - Note gaps in your filing --- ## CAS Numbers Explained ### What is a CAS Number? A CAS (Chemical Abstracts Service) Registry Number is a unique identifier assigned to every chemical substance. It's the global standard for chemical identification. ### Format CAS numbers follow the format: XXXXXXX-XX-X - First part: up to 7 digits - Second part: 2 digits - Third part: 1 check digit ### Why CAS Numbers Matter for PFAS Reporting EPA requires reporting at the chemical level, not the product level. You need CAS numbers to: - Identify specific PFAS in your products - Avoid duplicate reporting - Enable EPA's data aggregation - Demonstrate compliant reporting ### Example CAS Numbers for Common PFAS | Chemical | CAS Number | |----------|------------| | PFOA | 335-67-1 | | PFOS | 1763-23-1 | | GenX | 62037-80-3 | | PTFE | 9002-84-0 | | PFBS | 375-73-5 | | PFHxS | 355-46-4 | ### How to Obtain CAS Numbers 1. Request from suppliers 2. Check Safety Data Sheets (SDS) 3. Product technical specifications 4. Laboratory testing 5. Chemical databases (SciFinder, PubChem) ### When CAS Numbers Are Unknown If despite reasonable efforts you cannot determine the CAS number: - Report what you know (product category, properties) - Document attempts to obtain information - Use generic PFAS identifiers where permitted --- # Industry-Specific Guidance ## Textiles and Apparel ### Why This Industry Is Affected The textiles industry is one of the largest users of PFAS, primarily for water-resistant and stain-repellent treatments. ### Common PFAS Applications - Outdoor clothing (rain jackets, ski wear) - Athletic apparel (moisture-wicking fabrics) - Uniforms (military, industrial) - Carpets and rugs - Upholstery and furniture fabrics - Bedding and mattress covers ### Specific PFAS Used - PTFE coatings (Teflon) - Fluorotelomer-based treatments - Side-chain fluorinated polymers - C6 and C8 fluorocarbon finishes ### Compliance Challenges - Products imported from dozens of countries - Multiple suppliers per product line - Historical records may be incomplete - Suppliers may not know specific PFAS used ### Recommended Steps 1. Inventory all textile imports 2011-2022 2. Identify products with water/stain resistance claims 3. Contact suppliers for PFAS declarations 4. Consider testing samples of high-risk products 5. Document all data gathering efforts --- ## Electronics Industry ### Why This Industry Is Affected Electronics manufacturing relies heavily on PFAS for their unique properties in challenging environments. ### Common PFAS Applications - Semiconductor fabrication - Printed circuit boards - Wire and cable insulation - Heat-resistant gaskets and seals - Solder masks and flux - Thermal management materials ### Specific PFAS Used - PTFE (wire insulation) - PVDF (battery components) - FEP (cable jacketing) - Fluorinated solvents - Perfluoropolyethers (lubricants) ### Compliance Challenges - Complex multi-tier supply chains - Components from hundreds of suppliers - Rapid product lifecycles - Proprietary formulations ### Recommended Steps 1. Map your component supply chain 2. Prioritize high-PFAS-risk components 3. Engage tier-1 suppliers with formal requests 4. Request cascade inquiries to tier-2/3 suppliers 5. Document all responses and non-responses --- ## Automotive Industry ### Why This Industry Is Affected Vehicles contain numerous components that rely on PFAS for durability and performance. ### Common PFAS Applications - Fuel system components (hoses, seals) - Brake fluid - Transmission fluid additives - Weatherstripping and seals - Wire harness insulation - Seat fabric treatments - Underbody coatings ### Specific PFAS Used - Fluoroelastomers (Viton) - PTFE (seals and gaskets) - Fluorinated lubricants - Fluorosurfactants in fluids ### Compliance Challenges - Thousands of components per vehicle - Long model years (parts imported over many years) - Multiple tier suppliers - Aftermarket parts and accessories ### Recommended Steps 1. Focus on high-PFAS-risk component categories 2. Prioritize fuel system, seals, and treated fabrics 3. Engage parts suppliers systematically 4. Document by part number and supplier 5. Consider testing representative components --- ## Food Packaging ### Why This Industry Is Affected PFAS are widely used in food packaging for their grease and moisture resistance. ### Common PFAS Applications - Fast food wrappers and containers - Microwave popcorn bags - Pizza boxes - Bakery bags and boxes - Pet food bags - Disposable plates and bowls ### Specific PFAS Used - Fluorotelomer-based coatings - PFOA/PFOS (historical) - Short-chain PFAS (current) - Perfluoropolyethers ### Compliance Challenges - High volume, low value items - Multiple packaging suppliers - Products designed for single use - Historical formulation changes ### Recommended Steps 1. Identify all food-contact packaging imports 2. Prioritize grease-resistant items 3. Request PFAS declarations from suppliers 4. Check for "PFAS-free" claims and verify 5. Document import volumes by product type --- ## Cosmetics and Personal Care ### Why This Industry Is Affected PFAS are used in cosmetics for their long-wear and smooth application properties. ### Common PFAS Applications - Foundation and concealer - Mascara and eyeliner - Lipstick and lip gloss - Sunscreen - Shaving products - Hair styling products - Nail polish ### Specific PFAS Used - PTFE (smoothing agent) - Fluorinated silicones - Perfluorodecalin (oxygen carrier) - Fluorosurfactants ### Compliance Challenges - Complex multi-ingredient formulations - Proprietary formulas - Private label products - Rapidly changing product lines ### Recommended Steps 1. Inventory all imported cosmetic products 2. Request complete ingredient lists 3. Identify fluorinated ingredients (look for "fluor-" prefix) 4. Request CAS numbers for all fluorinated compounds 5. Document by product SKU and supplier --- ## Medical Devices ### Why This Industry Is Affected Medical devices use PFAS for their biocompatibility, lubricity, and chemical resistance. ### Common PFAS Applications - Implantable devices - Catheters and tubing - Surgical instruments - Drug delivery systems - Diagnostic equipment - Prosthetics - Wound dressings ### Specific PFAS Used - PTFE (implant coatings, tubing) - ePTFE (vascular grafts) - PVDF (membranes) - Fluoropolymer coatings ### Compliance Challenges - Highly regulated products - Long development cycles - Stringent documentation requirements - FDA compliance intersection ### Recommended Steps 1. Review device master files for PFAS content 2. Cross-reference with import records 3. Engage quality/regulatory teams 4. Contact component suppliers formally 5. Leverage existing supply chain documentation --- ## Construction Materials ### Why This Industry Is Affected Construction materials use PFAS for weatherproofing and durability. ### Common PFAS Applications - House wrap and weather barriers - Roofing membranes - Sealants and caulks - Paints and coatings - Carpeting and flooring - Insulation materials ### Specific PFAS Used - Fluoropolymer coatings - Fluorosurfactants in paints - PTFE tape and gaskets - Fluorinated waterproofing treatments ### Compliance Challenges - Products with long lifespans - Many distributors and importers - Building products often unbranded - Historical product formulations ### Recommended Steps 1. Identify water-resistant product categories 2. Review supplier technical data sheets 3. Request PFAS declarations 4. Test representative samples if needed 5. Document by product type and supplier --- ## Aerospace Industry ### Why This Industry Is Affected Aerospace applications demand extreme performance that PFAS uniquely provide. ### Common PFAS Applications - Hydraulic system seals - Fuel system components - Wire and cable insulation - Lubricants and greases - Anti-icing coatings - Interior fabrics and carpets ### Specific PFAS Used - PTFE seals and gaskets - Fluorocarbon elastomers - Perfluoropolyether lubricants - Fluoropolymer coatings ### Compliance Challenges - Defense contractor requirements - ITAR and export control considerations - Long product lifecycles (decades) - Complex tier-n supply chains ### Recommended Steps 1. Review component specifications for fluorinated materials 2. Prioritize fluid system components 3. Engage approved suppliers with formal requests 4. Document by part number and specification 5. Consider intersection with defense reporting --- # PFAS Chemical Reference ## Legacy PFAS (Long-Chain) ### PFOA - Perfluorooctanoic Acid - **CAS Number**: 335-67-1 - **Also Known As**: C8, Perfluorocaprylic acid - **Category**: Legacy long-chain PFAS - **Status**: Phased out in US by 2015 **What It Is** PFOA is an 8-carbon perfluorinated carboxylic acid that was a key processing aid in manufacturing PTFE (Teflon) and other fluoropolymers. It's one of the most studied and regulated PFAS. **Historical Uses** - Teflon manufacturing - Textile treatments (Gore-Tex, Scotchgard) - Food packaging coatings - Firefighting foams - Industrial surfactants **Why It's Reportable** Despite being largely phased out, any import or manufacture of PFOA or PFOA-containing products between 2011-2015 must be reported. Products containing residual PFOA may still be subject to reporting. **Health Concerns** - Classified as possible human carcinogen - Linked to kidney and testicular cancer - Associated with thyroid disease - Developmental effects - Immune system impacts --- ### PFOS - Perfluorooctane Sulfonate - **CAS Number**: 1763-23-1 - **Also Known As**: Perfluorooctanesulfonic acid - **Category**: Legacy long-chain PFAS - **Status**: Phased out globally under Stockholm Convention **What It Is** PFOS is an 8-carbon perfluorinated sulfonic acid. It was the active ingredient in 3M's Scotchgard fabric protector until 2002 and a key component of AFFF firefighting foams. **Historical Uses** - Scotchgard fabric protection - AFFF firefighting foams - Metal plating - Hydraulic fluids - Paper and packaging treatments **Why It's Reportable** PFOS was phased out earlier than PFOA, but products containing it may have been imported through 2011-2012. Stockpiled products and specialized applications continued longer. **Health Concerns** - Liver damage - Immune system effects - Developmental toxicity - Possible carcinogen - Thyroid disruption --- ### PFNA - Perfluorononanoic Acid - **CAS Number**: 375-95-1 - **Category**: Legacy long-chain PFAS - **Status**: Being phased out globally **What It Is** PFNA is a 9-carbon perfluorinated carboxylic acid, closely related to PFOA. It's found as an impurity in PFOA and in some fluoropolymer production processes. **Common Uses** - Fluoropolymer processing - Industrial coatings - Specialty chemicals - Byproduct of other PFAS manufacturing **Why It's Reportable** PFNA is a regulated long-chain PFAS with similar toxicity concerns as PFOA. Products containing it as an intentional ingredient or impurity require reporting. --- ### PFDA - Perfluorodecanoic Acid - **CAS Number**: 335-76-2 - **Category**: Legacy long-chain PFAS - **Status**: Restricted globally **What It Is** PFDA is a 10-carbon perfluorinated carboxylic acid used as an industrial surfactant and fluoropolymer processing aid. **Common Uses** - Industrial surfactants - Fluoropolymer production - Specialty chemical applications - Metal plating **Why It's Reportable** As a long-chain PFAS, PFDA is subject to the same reporting requirements as other legacy compounds. --- ## Replacement PFAS (Short-Chain) ### GenX - HFPO-DA - **CAS Number**: 62037-80-3 - **Also Known As**: HFPO Dimer Acid, Hexafluoropropylene oxide dimer acid - **Category**: Replacement PFAS - **Status**: Currently in use, under regulatory scrutiny **What It Is** GenX is a trade name for a processing technology and associated chemicals developed by Chemours as a replacement for PFOA in fluoropolymer manufacturing. **Current Uses** - PTFE production - Fluoropolymer manufacturing - Industrial processing aid **Why It's Reportable** GenX is a reportable PFAS under the structural definition. Despite being a "replacement" for legacy PFAS, it has its own toxicity concerns and requires reporting. **Health Concerns** - Liver effects - Kidney effects - Developmental toxicity - Under investigation for carcinogenicity --- ### PFBS - Perfluorobutane Sulfonate - **CAS Number**: 375-73-5 - **Category**: Short-chain replacement PFAS - **Status**: Currently in widespread use **What It Is** PFBS is a 4-carbon perfluorinated sulfonic acid used as a replacement for PFOS. It has a shorter half-life in humans than long-chain PFAS. **Current Uses** - Fabric and textile treatments - Industrial cleaning agents - Replacement for PFOS in various applications - Metal plating - Firefighting foams (some formulations) **Why It's Reportable** Despite being promoted as a safer alternative, PFBS meets EPA's structural definition of PFAS and requires reporting under TSCA 8(a)(7). **Health Concerns** - Thyroid effects (primary concern) - Kidney effects - Developmental effects - Less bioaccumulative than PFOS --- ### PFHxS - Perfluorohexane Sulfonate - **CAS Number**: 355-46-4 - **Category**: Transitional PFAS - **Status**: Being phased out, listed under Stockholm Convention **What It Is** PFHxS is a 6-carbon perfluorinated sulfonic acid that falls between short-chain and long-chain PFAS in terms of properties and persistence. **Historical Uses** - Firefighting foams - Fabric treatments - Industrial applications - Transitional replacement for PFOS **Why It's Reportable** PFHxS was added to the Stockholm Convention in 2022 due to its persistence and toxicity. Any historical import or manufacture requires reporting. **Health Concerns** - Thyroid effects - Liver damage - Developmental toxicity - Environmental persistence --- ### PFHxA - Perfluorohexanoic Acid - **CAS Number**: 307-24-4 - **Category**: Short-chain PFAS - **Status**: Currently in use as replacement **What It Is** PFHxA is a 6-carbon perfluorinated carboxylic acid used as a replacement for PFOA and other long-chain PFAS. **Current Uses** - Textile treatments - Paper coatings - Industrial surfactants - Food packaging **Why It's Reportable** As a PFAS meeting EPA's structural definition, PFHxA requires reporting regardless of its status as a "replacement" chemical. --- ## Fluoropolymers ### PTFE - Polytetrafluoroethylene - **CAS Number**: 9002-84-0 - **Also Known As**: Teflon (DuPont trademark) - **Category**: Fluoropolymer - **Status**: Widely used, manufactured using replacement processing aids **What It Is** PTFE is the polymer that makes up Teflon and many other non-stick and low-friction products. It's a high-molecular-weight polymer with exceptional chemical resistance. **Common Uses** - Non-stick cookware - Wire and cable insulation - Gaskets and seals - Industrial linings - Medical devices - Semiconductor manufacturing **Why It's Reportable** While PTFE itself is considered relatively inert, its manufacture historically used PFOA (and now uses GenX). Imported PTFE products may contain residual processing aids. The polymer itself meets the structural definition. **Special Considerations** - Very high volume of commerce - Present in countless product categories - Manufacturing residuals may be present - Degradation products may include smaller PFAS --- ### FEVE - Fluoroethylene Vinyl Ether - **CAS Number**: 28961-43-5 - **Category**: Fluoropolymer - **Status**: Currently in use for architectural coatings **What It Is** FEVE is a fluoropolymer used primarily in high-performance architectural coatings, providing exceptional weatherability and color retention. **Common Uses** - Architectural coatings - Industrial coatings - Automotive refinish - Aerospace coatings - Bridge and infrastructure coatings **Why It's Reportable** FEVE contains the fluorinated structures that define PFAS under EPA's rule and requires reporting if manufactured or imported. --- ## Fluorotelomers ### 6:2 FTS - 6:2 Fluorotelomer Sulfonate - **CAS Number**: 27619-97-2 - **Also Known As**: 6:2 Fluorotelomer sulfonic acid - **Category**: Fluorotelomer - **Status**: Currently in use, under increasing scrutiny **What It Is** 6:2 FTS is a fluorotelomer-based surfactant used as a replacement for PFOS in various applications, including firefighting foams. **Common Uses** - AFFF firefighting foams (newer formulations) - Industrial surfactants - Chrome plating - Semiconductor manufacturing **Why It's Reportable** Fluorotelomers are PFAS precursors and meet the structural definition. They can degrade into more persistent PFAS in the environment. **Health Concerns** - Can degrade to PFHxA and other PFAS - Environmental persistence - Aquatic toxicity - Under investigation for health effects --- # Frequently Asked Questions ## Am I Required to Report PFAS Under TSCA 8(a)(7)? ### Quick Answer If your company manufactured or imported PFAS or PFAS-containing articles at any time between January 1, 2011 and December 31, 2022, you are likely required to report under TSCA 8(a)(7). ### Detailed Explanation EPA's PFAS reporting rule has exceptionally broad coverage. Unlike typical TSCA reporting rules, there is no article exemption for importers—meaning companies that import finished goods containing PFAS have the same reporting obligations as chemical manufacturers. The rule covers any PFAS meeting EPA's structural definition (at least one fully fluorinated carbon atom), which includes thousands of compounds used in countless products. Small businesses are not exempt based on size, and there is no de minimis threshold for small quantities. The only significant exemptions are for certain R&D activities and specific byproduct situations. If you've imported or manufactured any products with water-resistant, stain-repellent, non-stick, or heat-resistant properties since 2011, you likely have reporting obligations. ### Key Points - No article exemption—importers of finished goods must report - No small business exemption based on company size - No de minimis exemption for small quantities - Covers all PFAS manufactured or imported since 2011 - Applies to both direct manufacturers and importers - Deadline is May 8, 2026 --- ## What If I Don't Know If My Products Contain PFAS? ### Quick Answer You must make reasonable efforts to determine PFAS content through supplier outreach, product testing, or reasonable estimates based on available information. ### Detailed Explanation Many importers face this challenge—especially for products imported years ago during the lookback period. EPA recognizes that perfect data may not be available and allows for reasonable estimates. However, you must document your efforts to obtain accurate information. Start by requesting PFAS declarations from suppliers for all potentially affected products. For suppliers who can't or won't provide data, consider laboratory testing for products with high risk (water-resistant, stain-repellent properties). For products where data is truly unavailable, you may report based on reasonable estimates using industry knowledge, product characteristics, and available scientific literature. Document all efforts thoroughly—this demonstrates good faith compliance even if your data is imperfect. ### Key Points - Request PFAS declarations from all suppliers - Document all attempts to obtain information - Consider lab testing for high-risk products - Reasonable estimates are acceptable when data unavailable - Good faith efforts reduce penalty exposure - Keep records of methodology used for estimates --- ## Is There a Small Business Exemption for PFAS Reporting? ### Quick Answer No. There is no small business exemption for PFAS reporting under TSCA 8(a)(7). Companies of all sizes must report if they manufactured or imported PFAS since 2011. ### Detailed Explanation Unlike some other EPA reporting requirements, TSCA 8(a)(7) contains no exemptions based on company size, revenue, or employee count. This is a deliberate policy choice by EPA—the agency determined that comprehensive PFAS data is essential regardless of company size. A sole proprietor importing water-resistant jackets has the same fundamental reporting obligations as a Fortune 500 company. The only relief for smaller entities is that the volume and complexity of their reporting may be simpler if they have fewer products and smaller quantities. But the obligation to report exists regardless of business size. This makes it especially important for small importers to begin compliance activities early, as they may have fewer resources to dedicate to data collection and filing. ### Key Points - No exemption based on company size or revenue - No exemption based on employee count - Small importers have same obligations as large companies - Reporting complexity may be lower for smaller operations - Penalties apply equally regardless of company size - Start early—small businesses may have fewer compliance resources --- ## What Is the PFAS Reporting Lookback Period? ### Quick Answer The lookback period is January 1, 2011 through December 31, 2022. You must report all PFAS manufacturing and import activity during this entire 12-year period. ### Detailed Explanation EPA's PFAS reporting rule is retroactive, requiring companies to report on historical activities spanning over a decade. This lookback period was chosen to capture both legacy PFAS (like PFOA and PFOS) that were phased out in the mid-2000s as well as replacement chemicals and ongoing uses. For importers, this means reviewing all product imports from 2011 through 2022 to identify any that may have contained PFAS. The challenge is significant: records may be incomplete, suppliers may have changed, and some products may no longer exist. However, EPA requires reporting to the extent records are reasonably available. You should gather import records, supplier documentation, product specifications, and any other information that can help identify PFAS-containing imports during this period. ### Key Points - Start date: January 1, 2011 - End date: December 31, 2022 - 12+ years of historical data required - Report to extent records are reasonably available - Covers both legacy and replacement PFAS - Filing deadline is May 8, 2026 --- ## What Are the Penalties for Not Reporting PFAS? ### Quick Answer Penalties can reach up to $50,000 per day per violation, with no cap on total fines. Each unreported PFAS chemical and each day of non-compliance can be treated as separate violations. ### Detailed Explanation TSCA provides EPA with significant enforcement authority, and the agency has indicated it will pursue violators of the PFAS reporting rule. Civil penalties are calculated based on factors including the nature and extent of violations, economic benefit gained, company size and ability to pay, compliance history, and good faith efforts. The $50,000 per day figure is adjusted for inflation and represents the statutory maximum. In practice, actual penalties vary based on circumstances, but can quickly reach millions of dollars for companies with extensive PFAS exposure or willful non-compliance. Beyond civil penalties, knowing or willful violations can trigger criminal penalties including fines and imprisonment. The most effective protection is timely, good-faith compliance—even imperfect compliance with documented good faith efforts significantly reduces penalty exposure. ### Key Points - Up to $50,000 per day per violation - Each unreported PFAS = potential separate violation - Each day of non-compliance = separate violation - Criminal penalties possible for willful violations - Good faith compliance efforts reduce exposure - No penalty cap—fines can reach millions --- # About PFAS Reporting 2026 PFAS Reporting 2026 provides free compliance assessment tools and resources for US importers and manufacturers facing the EPA TSCA 8(a)(7) reporting deadline. ## Our Tools ### Free Compliance Assessment A 2-minute assessment to determine if your company has PFAS reporting obligations based on your import/manufacturing history. ### Supplier Letter Templates Ready-to-use templates for requesting PFAS information from your supply chain. ### PFAS Chemical Database Searchable reference of reportable PFAS with CAS numbers, uses, and regulatory status. ## Contact Website: https://pfasreporting2026.com --- *This document is for informational purposes only and does not constitute legal advice. Consult with legal and compliance professionals for guidance specific to your situation.* *Last updated: January 2025*