What changed
EPA continues to use TSCA reporting and recordkeeping rules to require companies to submit chemical information needed for prioritisation, risk evaluation and risk management. Two current obligations need attention:
TSCA Section 8(d) — Health and Safety Data Reporting. EPA's Section 8(d) rule requires manufacturers, including importers, of 16 chemicals to report unpublished health and safety studies. EPA's 22 May 2026 final rule extended the submission deadline to 21 May 2027 for all 16 covered chemicals.
TSCA Section 8(a)(7) — PFAS Reporting and Recordkeeping. EPA's PFAS reporting rule requires persons that manufactured or imported PFAS — including in articles — in any year from 2011 through 2022 to report chemical identity, uses, production/import volumes, byproducts, environmental and health effects, worker exposure and disposal information. EPA postponed the start of the reporting period to 31 January 2027, or 60 days after the effective date of a forthcoming revision to the rule — whichever is earlier. Once the window opens, manufacturers have six months to submit.
Legal status
This is mandatory reporting and recordkeeping, not a voluntary survey. The Section 8(d) submission deadline is currently 21 May 2027; EPA says the extension gives time to consider modifications to scope, guidance and implementation while preserving the underlying data-collection purpose.
For PFAS under Section 8(a)(7), the obligation remains — only the start of the reporting window has moved. Companies should not treat the postponement as cancellation of the rule.
Why this needs attention
This is a major data-reconstruction and evidence-management issue. The required information may not sit only in Regulatory Affairs — it can be spread across R&D archives, toxicology files, industrial hygiene records, supplier documentation, SDS databases, import records, production data, historical formulations, waste and disposal records, and acquired-company archives.
For PFAS, the historical 2011–2022 period makes this particularly difficult: old suppliers, product codes, formulations and import records may no longer be easy to reconstruct.
Compliance impact
Companies may need to submit unpublished health and safety studies, chemical identity information, manufacturing/import volumes, use and processing information, byproduct information, worker exposure data, environmental release and disposal information, existing exposure monitoring data, and records supporting "not known or reasonably ascertainable" conclusions.
This is not a Hazard Communication classification update by itself. A chemical appearing in a TSCA reporting rule does not automatically require a new OSHA HCS classification or SDS label change — but any new health or safety information discovered during the reporting exercise should be evaluated through the company's formal HCS hazard-classification process.
Recommended actions
Build a TSCA reporting inventory
- Identify every US legal entity that manufactured or imported chemicals, and screen activities against Section 8(d) and 8(a)(7) scope.
- Include imported substances, mixtures and, where applicable, articles.
- Search by CAS number, trade name, generic name and supplier name, including historical lines from acquisitions and divestments.
Prepare TSCA 8(d) health and safety study reporting
- Confirm whether any of the 16 listed chemicals were manufactured or imported, and search for unpublished health and safety studies — toxicology, ecotoxicology, occupational exposure, environmental fate and industrial hygiene, where relevant.
- Determine whether each study is reportable, exempt or outside scope, and confirm study ownership and the right to submit.
- Prepare the submission well before 21 May 2027.
Prepare PFAS 8(a)(7) reporting
- Build a PFAS inventory covering 2011–2022, including substances, mixtures, imported articles, coatings, surface treatments, polymers, processing aids and impurities.
- Request historical PFAS data from suppliers and collect manufacturing/import volumes by year.
- Identify uses, byproducts, worker exposure, environmental releases and disposal routes, and document where information is not known or not reasonably ascertainable.
- Monitor EPA's forthcoming PFAS rule revision so the actual reporting-period start date can be calculated as soon as it's set.
Recordkeeping and audit trail
- Keep all source documents used for reporting decisions, and preserve supplier responses and non-response records.
- Maintain assumptions and calculation methods, and store submission receipts.
- Link submitted data to the relevant legal entity, chemical identity and reporting year.
- Run internal review by Regulatory Affairs, Legal, EHS and Supply Chain before submission.
Reviewed by CHEMREG Regulatory Team · Last reviewed 16 Sept 2026