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Reporting and Recordkeeping for Perfluoroalkyl and Polyfluoroalkyl Substances under Section 8(a)(7) of the Toxic Substances Control Act (TSCA)

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Jan 14, 2026
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closed 211d ago
National Association of Manufacturers (NAM) filings
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Activity

National Association of Manufacturers (NAM) filed 3 comments on this docket between Sep 29, 2021 and Dec 31, 2025. 112 other organizations filed here. The comment window closed 211d ago.

What National Association of Manufacturers (NAM) filed (3)

Dec 31, 2025· Comment submitted by National Association of Manufacturers (NAM)· EPA-HQ-OPPT-2020-0549-0669

Filed on regulations.gov — full text not in the inline record.

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Jun 17, 2025· Comment submitted by National Association of Manufacturers· EPA-HQ-OPPT-2020-0549-0298

Filed on regulations.gov — full text not in the inline record.

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Sep 29, 2021· Comment submitted by National Association of Manufacturers (NAM)· EPA-HQ-OPPT-2020-0549-0093

Manufacturers in the US are committed to the communities in which they live and serve, and dedicated to protecting the health, safety and vibrancy of those communities. Through constant innovation, investment and dedication, manufacturers in the US have become leaders in environmental stewardship and sustainability, while continuing to be the engine that drives our economic growth and prosperity. The manufacturing sector in the US today is a clean and efficient operation that is technology driven and dedicated to the planet and its people. The National Association of Manufacturers supports human health and environmental protection and is committed to ensuring that products are developed, manufactured, distributed and used safely. No goal is more important than safety to manufacturers. Every member of the value chain has an important part to play in ensuring the products consumers use are safe for their intended use, that the end customer knows how to use them safely and that their products have a sustainable end of life. Manufacturers welcome the opportunity to engage with EPA and others who share our commitment to product safety and environmental stewardship. Modern PFAS chemistries are used by a broad range of industries worldwide to make innovative products possible, including personal protective equipment, life-saving medical devices, fuel cells, solar panels, and low-emission vehicles. The NAM recognizes both the importance and the complexity of the task facing EPA in identifying, assessing and appropriately managing any potential risks that may be associated with specific chemistries within the broad universe of thousands of different PFAS chemistries, and manufacturers strongly support those efforts rooted in the best available science. To this end, TSCA Section 8(a)(7) provides EPA with an important tool for gathering information on the manufacture, processing and use of the broad array of PFAS compounds in the US, and the data obtained under the Section 8(a)(7) rule can provide valuable insights into patterns of PFAS use and exposure that will allow EPA to more effectively focus and prioritize its regulatory efforts. However, if not thoughtfully tailored, the Section 8(a)(7) rule, requiring reporting on more than a thousand different substances over a period of more than ten years, could create the potential for EPA to be overwhelmed by a large volume of information that is of questionable reliability and limited utility. Such a result could stall critical efforts to better understand these chemistries and be a roadblock to science-based regulatory approaches. Manufacturers take seriously these important chemical reporting measures and are committed to devoting the significant investments of time and resources to fully and accurately share this information with the EPA. The NAM submits the attached comments to ensure the success of this important effort. The NAM appreciates this opportunity to provide comments on the critically important TSCA Section 8(a)(7) rule and welcomes the opportunity to work collaboratively with EPA and other stakeholders to ensure that the rule can be successfully implemented in a manner that is practicable and protective of human health and the environment.

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Abstract

EPA is proposing amendments to a TSCA regulation for reporting and recordkeeping requirements for perfluoroalkyl and polyfluoroalkyl substances (PFAS). As promulgated in October 2023, the regulation requires manufacturers (including importers) of PFAS in any year between 2011-2022 to report certain data to EPA related to exposure and environmental and health effects. EPA is proposing to incorporate certain exemptions and other modifications to the scope of the reporting regulation. These exemptions would maintain important reporting on PFAS, consistent with statutory requirements, while exempting reporting on activities about which manufacturers are least likely to know or reasonably ascertain.

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Co-filers (112)

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