EPA Delays PFAS Reporting Start Date for a Third Time

The U.S. Environmental Protection Agency (EPA) has, for the third time, delayed the six‑month reporting window for manufacturers to submit PFAS use data.

The new trigger for the reporting period will begin either 60 days after the effective date of EPA’s forthcoming final rule revising the PFAS Reporting Rule or on January 31, 2027, whichever occurs earlier. EPA states January 31, 2027, is a backstop and expects to finalize the revisions well before that date and later remove the fallback date in the final rule.

Key Updates

• Previous start date of April 13, 2026, has been replaced.
• New start trigger: 60 days after the effective date of the forthcoming final rule revising the program, or Jan. 31, 2027, whichever is earlier.
• EPA describes Jan. 31, 2027, as an “added not-later-than commencement date” and expects to finalize and remove the fallback date with the final rule.
• EPA says the delay provides clearer direction and accountability to companies and gives the agency time to review thousands of public comments so it can refine the rule to deliver “timely, actionable reporting guidance without unnecessary loopholes.”

Implications for Manufacturers

• Preparations to compile PFAS use data should continue, but firms may have additional time before the formal six-month reporting window opens.
• Continue document retention and data collection, and monitor EPA publications for the final rule and its effective date.
• Evaluate current compliance processes and supplier communications to ensure rapid response once the reporting period is triggered.

Recommended Next Steps

• Maintain and update internal PFAS inventory and supporting documentation.
• Review reporting procedures to identify gaps and needed resources for a six‑month submission period.
• Monitor the Federal Register and EPA announcements for the final rule and any subsequent removal of the fallback date.
• Consider engaging regulatory counsel or compliance consultants to prepare for varied rule outcomes.

For assistance in reviewing your current PFAS data collection process and timeline or drafting a compliance action plan tailored to your operations, please contact Frantz Ward’s Environmental Practice Group.

This client alert is provided for informational purposes only and does not constitute legal advice. Readers should consult qualified counsel regarding specific circumstances.