EPA’S PFAS Reporting and Recordkeeping Compliance Requirements

The Environmental Protection Agency (EPA) has promulgated reporting and recordkeeping requirements for Per- and Polyfluoroalkyl Substances (PFAS) under the Toxic Substances Control Act (TSCA) section 8(a)(7). In accordance with obligations under TSCA, as amended by the National Defense Authorization Act for Fiscal Year 2020, EPA is requiring any person that manufactures (including import) or has manufactured (including imported) PFAS or PFAS-containing articles in any year since January 1, 2011, to electronically report information regarding PFAS uses, production volumes, disposal, exposures, and hazards.

To help the nonroad equipment manufacturing industry meet these new requirements, AEM and its member companies are providing a number of educational resources intended to outline the best practices for impacted stakeholder companies looking to comply with this new rule.

AEM Industry Best Practice Compliance Materials:

• AEM - Reference List of PFAS Chemicals Spreadsheet - EPA PFAS 8a7 Reporting and Recordkeeping Rule
• AEM - Data Requirements Spreadsheet - EPA PFAS 8a7 Reporting and Recordkeeping Rule
• AEM - Best Practice Document - EPA PFAS 8a7 Reporting and Recordkeeping Rule

Presentation Slide Deck:

• PFAS Reporting Update for AEM

AEM PFAS Position Paper:

• Per-and Polyfluoroalkyl Substances and the Non-Road Equipment Industry

EPA Reference Materials:

• EPA Direct Final Rule: PFAS Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Change to Submission Period
• EPA Final Rule: Toxic Substances Control Act Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances
• EPA General Instructions for Reporting PFAS under TSCA Section 8(a)(7)