Two active TSCA data-submission obligations need attention. Under Section 8(d), EPA extended the health and safety study reporting deadline for 16 listed chemicals to 21 May 2027. Under Section 8(a)(7), EPA's PFAS reporting rule covers manufacturing and import activity from 2011 through 2022; the reporting period's start has been postponed to 31 January 2027 or 60 days after a forthcoming rule revision takes effect, whichever is earlier — the obligation itself has not been cancelled.
Published16 Sept 2026EffectiveTSCA 8(d): submission deadline extended to 21 May 2027 for all 16 covered chemicals (final rule, 22 May 2026). TSCA 8(a)(7) PFAS: reporting period start postponed to 31 January 2027, or 60 days after the effective date of a forthcoming rule revision — whichever is earlier.Compliance deadline21 May 2027TSCA 8(d) health and safety study submissions are due 21 May 2027. TSCA 8(a)(7) PFAS reporting opens no later than 31 January 2027, with a 6-month submission window once it opens.
EPA's New Chemicals Program status pages show a familiar pattern: cases sitting in risk assessment, and cases waiting on the submitter to sign a consent order. The useful takeaway for companies is that regulatory delay is not always EPA's doing. Incomplete information, unresolved exposure data and slow internal order-signature workflows can add weeks or months to a launch. New-chemical approval is best run as a launch-readiness discipline, not a filing you hand off and wait on.
Published10 Sept 2026EffectiveObservation from EPA New Chemicals Program status pages, September 2026. No fixed date — review time depends on submission completeness and internal order-signature turnaround.
OSHA's updated Hazard Communication Standard (aligned to GHS Revision 7) had its compliance dates pushed back four months in January 2026. Chemical manufacturers, importers and distributors had to update substance SDSs and labels by 19 May 2026. Employers now have until 20 November 2026 to update workplace labels, the written HazCom programme, and training where new hazard information applies. Mixtures follow on 19 November 2027. This is no longer only a supplier SDS exercise — employers must turn the new hazard information into workplace communication.
Published10 Sept 2026EffectiveHCS 2024 in force since 19 July 2024; compliance dates extended four months in January 2026Compliance deadline20 Nov 2026Employers — substances: 20 November 2026. Manufacturers/importers/distributors — substances: 19 May 2026 (passed). All parties — mixtures: 19 November 2027.
EPA has refreshed its guidance for chemical importers. The core message for compliance teams: customs clearance is not the same as TSCA compliance. Before a chemical substance — on its own, in a mixture, or in some articles — enters US commerce, the importer needs to have checked TSCA Inventory listing and active/inactive status, any section 5 PMN or Significant New Use Rule, section 6 restrictions, Title VI formaldehyde requirements for composite wood, and the TSCA import certification. These checks belong in the import process, not after the goods arrive.
Published10 Sept 2026EffectiveOngoing obligation; EPA import guidance refreshed September 2026. No fixed deadline — the checks belong before each shipment and customs entry.