SPAN Submits Comments to EPA on Proposed TSCA Section 8(a)(7) PFAS Reporting Rule

On December 29, the Sustainable PFAS Action Network (SPAN) submitted a comment letter to the U.S. Environmental Protection Agency (EPA) in response to the Agency’s proposed amendments to the Toxic Substances Control Act (TSCA) Section 8(a)(7) PFAS Reporting Rule, reinforcing SPAN’s role as a leading stakeholder in the development of practical, science-based PFAS policy. 

The TSCA PFAS Reporting Rule requires manufacturers and importers to report extensive information on PFAS substances manufactured between 2011 and 2022. EPA’s proposed amendments seek to introduce targeted exemptions and scope clarifications to better align the rule with TSCA’s statutory framework and the realities of PFAS supply chains.

In its comments, SPAN expressed broad support for EPA’s proposed approach, recognizing the Agency’s efforts to ensure it is both effective and practicable. SPAN emphasized that the proposed amendments appropriately focus reporting obligations on activities where reliable historical information is most likely to exist. This adjustment is critical to ensuring both the usefulness of the data collected and the feasibility of compliance.

Drawing on the technical and operational expertise of its members, SPAN also provided EPA with concrete recommendations to further refine the rule. These include additional burden-reduction opportunities such as increased flexibility in study reporting formats and targeted refinements to the scope of reportable PFAS to address challenges faced by downstream users and importers.

SPAN’s comments underscore the coalition’s commitment to constructive engagement with regulators and its ongoing role in helping EPA strike the right balance between robust PFAS oversight and workable regulatory requirements. As the rulemaking moves forward, SPAN will continue to engage with EPA to ensure the final rule supports science and risk-based PFAS decision-making that protects human health and the environment while preserving the essential uses of PFAS critical to U.S. economic growth and global competitiveness.

Read the full comment letter here.