EPA Proposes Revisions to PFAS Reporting Requirements Under TSCA

The EPA has proposed revisions to its perfluoroalkyl and polyfluoroalkyl substances (PFAS) reporting rule under TSCA. The updates are intended to streamline compliance, clarify key provisions, and focus reporting on information most likely to be available to manufacturers and importers.

 

EPA finalized the original one-time PFAS reporting and recordkeeping rule in October 2023 under TSCA section 8(a)(7). That rule requires entities that manufactured or imported PFAS at any time from 2011–2022 to report information on uses, exposures, and any known environmental or health effects. According to EPA, since finalization, industry stakeholders and small businesses have expressed concerns regarding the scope of the requirements, associated costs, and challenges with implementation.

 

Key proposed exemptions include:

 

EPA is also proposing technical adjustments to clarify reporting expectations in several data fields and to revise the submission timeline.

 

Upon publication of the Federal Register notice, EPA will accept comments on the proposed changes for 45 days in docket #EPA-HQ-OPPT-2020-0549 on www.regulations.gov.

 

A college whose employees raised concerns about dampness and mold in campus buildings was the site of a NIOSH investigation described in a recently published health hazard evaluation (HHE) report. The hundred-acre campus had 14 buildings where approximately 420 people worked. Some 1,100 students attended the college.

 

Employee concerns about moisture and mold had been reported since the 1980s but increased after completion of a campus-wide water chiller system in 2018. Health complaints were varied and included irritation of the eyes, nose, and throat; nausea; vomiting; headaches; sensitivity to light; hearing loss; and other effects.

 

At the request of the employees’ union, NIOSH investigators visited the campus in August 2022 and March 2023. The investigation involved review of indoor air sampling reports and ventilation diagrams, meetings with employees, and inspections of several buildings. NIOSH found high indoor humidity, condensation leaking from ventilation systems, the absence of vapor barriers in crawl spaces, and campus-wide concerns with mold and moisture. The agency’s recommendations included actions to prevent groundwater from entering basements and crawl spaces; maintaining ventilation systems according to ASHRAE 62.1-2022, Ventilation for Acceptable Indoor Air Quality; correcting sources of dampness; and remediating building materials damaged by mold and moisture.

 

The report notes the uncertainty of identifying specific causes for health effects related to moisture. “In addition to fungi, indoor dampness is also associated with other allergenic organisms such as dust mites and bacteria, and these may also contribute to adverse health effects,” the report reads. “What building occupants react to is largely unknown. It can be mold, a compound produced by mold, something related to bacteria, or compounds that are released into the air when wet building materials break down.”

 

The HHE report is dated June 2025 but only recently became available on the NIOSH website.

 

 

ICAO will deliver a formal statement and submission to the United Nations Climate Change Conference (COP30), taking place next week in Belém, Brazil. This follows the global consensus reached on aviation environmental policies and framework under ICAO’s leadership at its recent Assembly. 

 

The statement to the sixty-third session of the UNFCCC Subsidiary Body for Scientific and Technological Advice (SBSTA 63) will focus on updates such as: 

 

ICAO’s submission reports on progress on ICAO’s Implementation Roadmap, including the Long-Term Global Aspirational Goal (LTAG) of net-zero carbon emissions by 2050, the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), ACT-SAF Programme and Finvest Hub.

 

The ICAO delegation will also host a side event entitled “International Aviation and UN Sustainable Development Goal (SDG) 7: Clean Energy”, to highlight the initiatives by the international aviation sector on Sustainable Aviation Fuels (SAF), Lower Carbon Aviation Fuels (LCAF), and other cleaner energies and to demonstrate how these efforts contribute to the broader clean energy transition to SDG 7. 

 

Through ICAO's leadership, the recent Assembly concluded with the adoption of three environmental Resolutions on climate change, CORSIA, and general provisions on noise and local air quality to further strengthen air transport’s global framework for decarbonization and environmentally responsible development.

 

ICAO’s upcoming engagement at COP30 represents an opportunity to drive accelerated climate action and implementation by Member States, international organizations, and other stakeholders to ensure that global air transport continues to decrease its environmental impact.

 

 

EPA has extended several deadlines for compliance with its May 2024 final rule that banned most uses of methylene chloride under the Toxic Substances and Control Act. Industrial and commercial facilities in which methylene chloride is used that are not operated by federal agencies or contractors have an additional 18 months to meet the workplace chemical protection program (WCPP) requirements set by the May 2024 rule. After the deadline extension rule goes into effect on Dec. 15, non-federal laboratories will share the same compliance dates as federally operated and contracted labs. Facilities will have until Nov. 9, 2026, to comply with initial monitoring requirements, until Feb. 8, 2027, to establish regulated areas and comply with the existing chemical exposure limit (ECEL) for methylene chloride, and until May 10, 2027, to comply with EPA’s exposure limits and develop and implement exposure control plans. The final rule establishes an ECEL for methylene chloride of 2 ppm as an eight-hour, time-weighted average. The OSHA permissible exposure limit for methylene chloride is 25 ppm as an eight-hour TWA.

 

The pre-publication notice states that EPA is extending these deadlines to “mitigate the unanticipated hardships inadvertently created for non-Federal laboratories by the WCPP compliance dates” established by the 2024 final rule. Comments received by the agency described challenges in complying with the WCPP requirements, such as the inability to substitute less toxic solvents when using EPA-mandated analytical methods and the cost of employing industrial hygienists to conduct initial monitoring.

 

Aligning the compliance deadlines for federal and non-federal labs will lessen the risk of these functions being disrupted and minimize confusion, according to EPA.

 

For more information, see EPA’s webpage on risk management for methylene chloride and the 2024 final rule.

 

 

The Candidate List of substances of very high concern (SVHC) now contains 251 entries for chemicals that can harm people or the environment. Companies are responsible for managing the risks of these chemicals and giving customers and consumers information on their safe use.

 

Helsinki, 5 November 2025 – ECHA’s Member State Committee confirmed the addition of 1,1'-(ethane-1,2-diyl)bis[pentabromobenzene] (DBDPE) to the list in its October meeting. The substance has very persistent and very bioaccumulative properties and is used as a flame retardant in various industries. This identification will support the potential restriction work on brominated flame retardants.

 

Entry added to the Candidate List on 5 November 2025:

 

The list now contains 251 entries – some are groups of chemicals, so the overall number of impacted chemicals is higher.

 

This substance may be placed on the Authorisation List in the future. If a substance is on this list, companies cannot use it unless they apply for authorization and the European Commission authorizes its continued use.

 

 

Under REACH, companies have legal obligations when their substance is included – either on its own, in mixtures or in articles – in the Candidate List.

 

If an article contains a Candidate List substance above a concentration of 0.1 % (weight by weight), suppliers have to give their customers and consumers information on how to use it safely. Consumers have the right to ask suppliers if the products they buy contain substances of very high concern.

 

Importers and producers of articles have to notify ECHA if their article contains a Candidate List substance within six months from the date it has been included in the list (5 November 2025).

 

EU and EEA suppliers of substances on the Candidate List, supplied either on their own or in mixtures, have to update the safety data sheet they provide to their customers.

 

Under the Waste Framework Directive, companies also must notify ECHA if the articles they produce contain substances of very high concern in a concentration above 0.1 % (weight by weight). This notification is published in ECHA’s database of substances of concern in products (SCIP).

 

Under the EU Ecolabel Regulation, products containing SVHCs cannot have the ecolabel award.

 

 

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