EPA’s PFAS Reporting Rule Requires Data Going Back to 2011

On September 28, 2023, the U.S. Environmental Protection Agency (EPA) released its final Toxic Substances Control Act (TSCA) Section 8(a) reporting rule. It expands reporting and recordkeeping requirements for companies that have manufactured or imported per- and polyfluoroalkyl substances (PFAS) for a commercial purpose—whether as a chemical substance or in a mixture or article—since January 1, 2011. Entities subject to this rule will need to submit reporting forms for retrospective data either 18 or 24 months following the rule’s effective date, which is 30 days after its publication in the Federal Register.

Read the full Alert on the Duane Morris LLP website.

PFAS

Per- and Polyfluoroalkyl substances (PFAS), sometimes called “forever chemicals,” are rising in public awareness, government regulation and related litigation. Companies that currently use or historically used or manufactured products containing PFAS are subject to increasing regulation and potential liability associated with the use, the impact on the environment, reporting and disposal of PFAS. Duane Morris’ dedicated group of professionals monitor, analyze and counsel clients on various aspects of PFAS, including companies who are developing technology to capture and eradicate PFAS from water and solids.