US EPA PFAS Reporting Rule (TSCA 8(a)(7)): “Infinite Chemicals” and What Turkish Exporters Need to Know

Why Now? It's an Inventory Rule, Not a Sales Ban.

The U.S. Environmental Protection Agency (EPA) imposed a one-time, retrospective reporting obligation under Section 8(a)(7) of the Toxic Substances Control Act (TSCA) for the family of chemicals known as PFAS. The rule expired in October 2023 and requires anyone producing or importing PFAS into the U.S. (including those importing them embedded in products) to declare aggregate data on past production, use, volume, disposal, and exposure, effective January 1, 2011.

There's a crucial distinction here: This is a reporting/inventory rule, not a ban on sales or use. The EPA wants to map where, in what volumes, and in which products PFAS are found in the US market. So the rule doesn't directly prevent your product from being sold in the US; it requests historical information. However, this information forms the basis for future restrictions and state-level bans.

The most striking aspect of the rule is its broad scope. Including importers of "articles" (substances embedded in products) means that sectors traditionally excluded from chemical reporting, such as textiles, coatings, packaging, and electronics, are facing this kind of obligation for the first time.

• Legal basis: TSCA Section 8(a)(7) — federal rule terminated in October 2023.
• Retrospective scope: All activities from January 1, 2011 to the present.
• Nature: One-time bulk reporting/inventory — NOT a sales ban.
• Information to be declared: areas of use, production/import volumes, disposal, exposure and known hazard data.
• Scope: includes both importers of pure PFAS chemicals and those importing finished products containing PFAS.

What are PFAS and why are they called "Infinite Chemicals"?

PFAS (per- and polyfluoroalkyl substances) are a large family of thousands of synthetic chemicals. Their common characteristic is that they contain extremely strong carbon-fluorobonds. These bonds provide exceptional resistance to water, oil, heat, and staining; therefore, they have found a very wide range of uses, from non-stick cookware and waterproof fabrics to food packaging and fire-fighting foams.

This same persistence translates into an environmental problem: these chemicals hardly break down in nature and in the human body, accumulating instead. This is where the nickname “forever chemicals” comes from. Health and environmental concerns led the EPA to first map the true prevalence of these substances in the U.S. economy, and then to make risk-based decisions. Rule TSCA 8(a)(7) is the data collection leg of this mapping step.

The important point for Turkish manufacturers is this: You may not be knowingly using PFAS, but it may have entered your product through a coating, finish, ink, or component in your supply chain. Therefore, the assumption that "we don't use PFAS" is not secure without technical verification.

• PFAS = a large family of synthetic chemicals consisting of thousands of substances.
• Key feature: water, oil, heat and stain resistance — thanks to the durable carbon-fluorine bond.
• Common applications: water/stain resistant textile finishes, non-stick and technical coatings, food contact packaging, some electronic components, carpets.
• “The reason it is "infinite": it does not break down in nature and in organisms, it accumulates.
• Risk of latent exposure: PFAS mostly enter the product indirectly through finishing/coating/component processes in the supply chain.

Who Should Report? Coverage of “Articles” (PFAS Embedded in the Product)

According to the original text of the rule, the obligation covers any legal or natural person who has produced or imported PFAS into the US since January 1, 2011. "Importing" is interpreted broadly here: it includes both importing pure PFAS chemical and importing an article containing PFAS. This "articles" directly applies to sectors such as textiles, coatings, packaging, electronics, and carpets.

It is important to emphasize that the responsibility lies with the importer in the US. Technically, the report is issued by the importer entering the US (importer of record). However, in practice, this indirectly affects the Turkish exporter: your US buyer will request a declaration and data regarding the PFAS content in your product. Failure to provide this declaration can lead to contractual risk and loss of the buyer.

An important development: In a draft proposal published in November 2025, the EPA suggested six new exemptions, including a general exemption for imported articles. If this proposal is finalized, the reporting obligation for those importing only PFAS embedded in their products could be largely eliminated. However, as of August 2026, this proposal is still in draft form and not finalized. Therefore, it is still prudent to base current planning on the assumption that you are still covered.

• Obligor: The person/company that has been producing or importing PFAS into the United States since January 1, 2011.
• “"Import" includes both pure chemicals and finished products (articles) containing PFAS.
• Typical products directly covered include: water/stain-resistant textiles, technical/non-stick coatings, food packaging, carpets, and some electronics.
• The legally responsible party is the importer in the US; however, the data request is passed on to the Turkish manufacturer via the supply chain.
• ATTENTION: The November 2025 draft proposal envisages a general exemption for imported products — but is NOT YET FINAL (draft).

Current Reporting Schedule: Why Has It Been Repeatedly Delayed?

The reporting window dates have been postponed several times since the rule was finalized — a major source of confusion. Initially, the window was to open in November 2024. Then it was pushed back to July 2025, then to April 2026, and the deadline for general manufacturers was announced as October 13, 2026. The postponements were largely justified by the EPA's need to prepare its data collection software and budget/staffing constraints; an operational reason, not a policy rollback.

The most recent and binding development is the final action dated April 13, 2026. With this regulation, the EPA moved the start of the window from April 13, 2026, to 60 days after the revised rule goes into effect OR January 31, 2027—whichever is earlier. Therefore, as of August 2026, there is no clear, definitive reporting window yet; the start is expected to be in the early months of 2027, but this date could shift depending on the final revision the EPA issues.

This postponement is directly linked to the proposed scope-narrowing changes (six new exemptions and a shorter reporting window) in November 2025. The EPA will determine both the core revision and the window duration in a separate final rule after evaluating thousands of public comments. In short: the timeline is not yet fixed and is likely to be updated once more in the coming months.

• The delay chain: November 2024 → July 2025 → April 2026 (start); the overall manufacturer's completion was announced as October 13, 2026.
• Final action date: April 13, 2026: commencement date now January 31, 2027 OR 60 days after the revised rule comes into effect — whichever is earlier.
• August 2026 situation: DEFINITE, NO open window; start most likely early 2027.
• The deadline for small business + imported-only article reporting was previously set as April 13, 2027; however, due to the April 2026 reboot and the proposed article exemption, this date has also become uncertain.
• Reason for postponement: software preparation, budget and staffing constraints + scope revision review — not a policy rollback.

What does this mean for Turkish manufacturers?

In the short term, the most tangible impact will be seen in data requests from your US buyers. If you export water/stain-resistant textiles, technical coatings, food packaging, carpets, or electronic components that may contain PFAS, your US importer may request a declaration regarding the presence, concentration, and intended use of PFAS in your product. Keeping this declaration ready and verified is more a matter of business continuity than a compliance obligation.

Despite the uncertainty, the healthy approach is not to “wait” but to “be prepared”: map the materials (finishs, coatings, inks, membranes) in your supply chain that may contain PFAS; collect material declarations from your suppliers; and verify with independent testing when necessary. This preparation will allow you to act quickly when federal reporting becomes clearer and will protect you against state-level bans, which we will discuss in the next paragraph.

Finally, it is important not to confuse this federal reporting rule with the PFAS sales bans imposed by some US states. These are separate legal regimes. For example, states like Maine and California have their own laws that gradually ban or require declaration of products containing PFAS in certain product categories (packaging, textiles, carpets, some consumer goods). Therefore, a PFAS that is only "reported" at the federal level may be "sold" in a specific state. Turkish exporters need to evaluate both federal (EPA/TSCA) and target state legislation separately.

• The immediate impact: Your US buyer's supply chain data/declaration request — critical for business continuity.
• Preparation steps: Map materials that may contain PFAS, collect supplier declarations, and verify with independent testing if necessary.
• “The assumption that "we don't use it" is not sufficient — confirm indirect PFAS presence through finishes/coatings/components.
• Federal reporting ≠ state ban: States like Maine and California have SEPARATE PFAS sales/declaration bans.
• Strategy: complete preparations early even if the timeline is uncertain; act quickly once things become clearer.

Frequently Asked Questions

We believe we don't use PFAS in our product. However, does this regulation still apply to us?

You probably need to check. PFAS usually enters a product indirectly, not as a conscious additive, but through intermediate materials such as water/stain repellent finishes, technical coatings, inks, or membranes. Therefore, the assumption of “PFAS-free” without technical verification (supplier declaration and testing where required) is not safe. Since the rule also covers those importing PFAS-containing products into the US, you may be indirectly affected through your supply chain.

Who does the reporting, the Turkish exporter or the US importer?

The legal obligation lies with the importer of record entering the US; they submit the report to the EPA. However, in practice, your US buyer will request declarations and data from you regarding the PFAS content in your product in order to complete their report. Therefore, although the legal obligation is not yours, the commercial responsibility and the expectation of providing data are reflected throughout the supply chain.

When exactly does the reporting window open? What happens if I miss it?

As of August 2026, there is no definitive, clear window yet. The start date was moved by the EPA action of April 13, 2026, to January 31, 2027, OR 60 days after the revised rule goes into effect (whichever is earlier), and the timeline will be determined by a separate final rule. So the timeline has most likely shifted to early 2027, but it is still subject to change. Due to this uncertainty, the safest approach is to regularly check the official dates on epa.gov and prepare your data in advance.

I heard there will be an exemption for imported products. Will reporting no longer be required?

It's too early to be sure. In a draft proposal published in November 2025, the EPA suggested six new exemptions, including a general exemption for imported articles. If this proposal becomes final, those importing only PFAS embedded in their products could be largely relieved of their obligations. However, this is a DRAFT; it is not final. Until it is finalized, it would be prudent to plan assuming you are covered.

Does this rule prohibit us from selling products containing PFAS to the US?

No. TSCA 8(a)(7) is a reporting/inventory rule; it is not a sales or use ban. It requires historical information (use, volume, exposure). However, do not confuse this with separate PFAS sales bans imposed by some US states (e.g., Maine, California) on specific products. A substance that is 'reported' at the federal level may face a 'sell' restriction in the target state; the two regimes should be considered separately.

This content is for informational purposes only and does not constitute legal opinion or compliance assessment. Current official sources from the relevant country should be consulted for precise obligations.