Multi-State PFAS Reporting Requirements
US PFAS reporting is not one rule but several, moving on different clocks: a federal TSCA rule whose submission window has not yet opened, and state programs in Maine, Minnesota and Washington already in motion — one of which has already passed a deadline this year.
Last reviewed September 27, 2026
Overview
TSCA Section 8(a)(7) requires manufacturers (including importers) who made PFAS for a commercial purpose any time from January 1, 2011 through December 31, 2022 to report exposure, use, production-volume, byproduct, disposal and health/environmental-effects data to EPA — a one-time historical report, not an annual one.
As of this review, the TSCA 8(a)(7) submission period has not opened. Per 40 CFR § 705.20 (91 FR 18789), it opens no later than January 31, 2027, or earlier if EPA’s final rule on its November 2025 proposal (90 FR 50923) takes effect before about December 2, 2026, since the period starts 60 days after that rule’s effective date.
Separately, EPA designated PFOA and PFOS as CERCLA hazardous substances (effective July 8, 2024) and has added PFAS to the annual Toxics Release Inventory list every year since reporting year 2020, most recently adding a further PFAS effective reporting year 2026 — both distinct from the one-time TSCA 8(a)(7) report.
Maine, Minnesota and Washington each run their own PFAS-in-products programs, with different reporting deadlines, sales-prohibition schedules and exemption mechanisms; Minnesota's initial reporting deadline (September 15, 2026) has already passed as of this review.
TSCA 8(a)(7), Maine, Minnesota and Washington obligations
- Federal (TSCA 8(a)(7)): manufacturers/importers of PFAS for a commercial purpose 2011–2022 must submit the required report once the submission period opens; article importers remain in scope under the current rule (a November 2025 proposal to add exemptions for hard-to-know activities is still pending, not yet final).
- Maine: sales of products with intentionally added PFAS are prohibited in stages by product category, running from January 1, 2023 through January 1, 2040, with a general ban (absent an approved Currently Unavoidable Use) starting January 1, 2032. The general PFAS notification requirement that used to apply ahead of the ban was eliminated by a 2023 amendment; notification now applies only to CUU-approved categories.
- Minnesota (Amara’s Law): manufacturers of products with intentionally added PFAS must report to the MPCA — the implementing rule set the initial deadline at September 15, 2026. Eleven product categories have been banned from sale since January 1, 2025; a general ban (absent further exemption) begins January 1, 2032.
- Washington: WAC 173-337 requires manufacturers to restrict or report PFAS in aftermarket stain- and water-resistance treatments, carpets/rugs, and leather/textile furnishings; separate, narrower rules cover PFAS in food packaging and in firefighting foam/PPE.
Deadlines
- July 8, 2024EPA’s CERCLA hazardous-substance designation for PFOA and PFOS takes effect. Federal Register — document 2024-08547 — as of 2026-09-27
- January 1, 2025Minnesota’s sales ban takes effect for 11 named product categories with intentionally added PFAS (carpets/rugs, cleaning products, cookware, cosmetics, dental floss, fabric treatments, juvenile products, menstruation products, textile furnishings, ski wax, upholstered furniture). Minnesota Revisor of Statutes — Minn. Stat. § 116.943 — as of 2026-09-27
- January 1, 2026Maine’s sales-prohibition schedule reaches its second stage: cleaning products, cookware, cosmetics, dental floss, juvenile products, menstruation products, textile articles (with exception), ski wax and upholstered furniture. Maine DEP — PFAS in Products — as of 2026-09-27
- February 27, 2026EPA finalizes the addition of an additional PFAS to the annual Toxics Release Inventory list, effective for reporting year 2026 onward. Federal Register — document 2026-03944 — as of 2026-09-27
- September 15, 2026Minnesota's initial PFAS-in-products report deadline under the implementing rule, Minn. R. ch. 7026 — already passed as of this review. Minnesota Pollution Control Agency — PFAS in Products Reporting and Fees — as of 2026-09-27
- January 31, 2027Outer backstop date for the federal TSCA 8(a)(7) submission period to begin, per 40 CFR § 705.20 (91 FR 18789). The actual start could be earlier — if EPA’s final rule on its November 2025 proposal (90 FR 50923) takes effect before about December 2, 2026, the period starts 60 days after that rule’s effective date instead — but as of this review the period has not opened and no report is yet due. eCFR — 40 CFR § 705.20 (91 FR 18789) — as of 2026-09-27
- January 1, 2032Maine’s general PFAS sales ban takes effect for all products with intentionally added PFAS, unless a Currently Unavoidable Use applies. Maine DEP — PFAS in Products — as of 2026-09-27
- January 1, 2032Minnesota's general PFAS sales ban takes effect for any product with intentionally added PFAS, absent further commissioner exemption. Minnesota Revisor of Statutes — Minn. Stat. § 116.943 — as of 2026-09-27
How Rumzer Helps
- PFASTracker's in-app email lets you collect PFAS-related information from suppliers and store technical documentation and chemical-composition detail for your entire product BOM.
- Rumzerbot analyzes complex BOMs to identify where PFAS-containing components are used in your finished goods, reducing manual analysis.
- PFASTracker checks substances against US EPA PFAS lists as provided in CompTox, so you can screen your own BOM data against the same lists regulators reference.
Frequently asked questions
What is TSCA 8(a)(7)?
TSCA Section 8(a)(7) is a federal EPA rule requiring manufacturers and importers who made PFAS for a commercial purpose between January 1, 2011 and December 31, 2022 to submit a one-time report on their use. As of this review, EPA has not yet opened the submission window — see the deadline above.
When does the PFAS reporting rule start?
Under 40 CFR § 705.20 (91 FR 18789), it opens no later than January 31, 2027, or earlier if EPA’s final rule on its November 2025 proposal (90 FR 50923) takes effect before about December 2, 2026, since the period starts 60 days after that rule’s effective date. No submission is due yet.
Does TSCA 8(a)(7) apply to article importers?
Yes — as promulgated, the rule reaches manufacturers whose only reporting-triggering activity is importing PFAS-containing articles. A pending 2025 proposal would add narrow exemptions for activities manufacturers are unlikely to know about, but it is not yet final, so the article-importer obligation remains in the current rule.
Does Maine ban PFAS?
Maine is phasing in sales prohibitions by product category from 2023 through 2040, with a general ban on intentionally added PFAS (absent an approved Currently Unavoidable Use) starting January 1, 2032.
What is Minnesota's PFAS reporting deadline?
Minnesota's implementing rule set the initial reporting deadline at September 15, 2026, which has already passed. Eleven product categories have been banned from sale since January 1, 2025, and a general ban follows January 1, 2032.
Keep reading
Sources
- EPA — TSCA Section 8(a)(7) Reporting and Recordkeeping — fetched 2026-09-27
- eCFR — 40 CFR Part 705 — fetched 2026-09-27
- Federal Register — document 2024-08547 (PFOA/PFOS CERCLA designation) — fetched 2026-09-27
- Federal Register — document 2026-03944 (TRI PFAS addition) — fetched 2026-09-27
- EPA — PFAS — fetched 2026-09-27
- EPA — CompTox chemistry tools — fetched 2026-09-27
- Maine DEP — PFAS in Products — fetched 2026-09-27
- Minnesota Pollution Control Agency — PFAS in Products Reporting and Fees — fetched 2026-09-27
- Minnesota Revisor of Statutes — Minn. Stat. § 116.943 — fetched 2026-09-27
- Washington Department of Ecology — PFAS — fetched 2026-09-27
See also: the US TSCA explainer · the compliance glossary
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