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New EPA PFAS Reporting Rule Imposes Significant Burdens on Consumer Product Importers

The US Environmental Protection Agency recently finalized a regulation under Section 8(a)(7) (15 U.S.C. Section1607(a)(7)) of the federal Toxic Substance Control Act (TSCA) requiring businesses to submit a one-time report about per- and polyfluoroalkyl substances (PFAS) that they have manufactured or imported for each year from January 1, 2011 through December 31, 2022. This reporting obligation also is imposed on importers (but not U.S. domestic manufacturers) of articles containing PFAS, e.g., consumer products containing PFAS. The deadline for submitting this one-time report is May 8, 2025. Importers of articles who qualify as “small” as defined under the rule (based on…

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