On November 10, 2025, the U.S. Environmental Protection Agency (EPA) proposed amendments to the Toxic Substances Control Act (TSCA) Section 8(a)(7) rule that requires anyone who manufactured or imported PFAS in the U.S. from 2011–2022 to report on those substances. While the rule itself isn’t going away, the EPA’s proposal could modify certain requirements, including exemptions that would remove reporting obligations for importers of articles containing PFAS.
For many manufacturers, this may seem like an opportunity to pull back the throttle on PFAS projects. But that would imply that TSCA is the only PFAS-related regulation out there. In reality, the number of PFAS-related laws — some requiring reporting and disclosure, and others outright banning its use — continue to grow around the world.
Even if your company would benefit from one of the new proposed exemptions to TSCA Section 8(a)(7) reporting, there are many other reasons why you need to accelerate your PFAS elimination program.
1. State-Level Regulations Are Accelerating
Beyond federal PFAS reporting requirements, U.S. states like Minnesota, Maine, and New Mexico are implementing their own state PFAS reporting laws. And beyond reporting, dozens of states have outright bans on the use of PFAS in a growing number of products.
The Oregon Environmental Council has made it clear that states will act where federal protections fall short. When California Governor Gavin Newsom vetoed his state’s PFAS reporting bill in 2022, it was because the federal EPA was preparing its own rule. If that federal rule is now weakened, expect state leaders to quickly step back in.
Unlike lengthy federal processes, state laws can move from proposal to enforcement in a matter of months. Minnesota’s groundbreaking Amara’s Law, for example, was enacted just four months after it was conceived, with the first bans taking effect less than two years later. Don’t assume federal exemptions will reduce your work. You may soon find yourself navigating a patchwork of even more state-specific regulations instead.
2. Global PFAS Restrictions Are Expanding Rapidly
Beyond the U.S., the European Union is moving forward with one of the most comprehensive PFAS restrictions ever proposed under the Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) Regulation. Sector-by-sector evaluations are nearly complete, with finished assessments expected in 2026 and a final law published as soon as 2027.
Unlike TSCA 8(a)(7), which is essentially a one-time data call about PFAS manufacture or import, EU REACH will force companies to design their products without PFAS or, at the very least, engage with regulators for essential use considerations. Redesigning products to eliminate PFAS will take years to complete. Manufacturers need to identify PFAS in their products and processes now, while there’s still time to find and qualify alternatives and avoid supply chain disruption.
Beyond the U.S. and EU, we continue to see global growth of PFAS restrictions and other obligations around the world. Canada and Japan both had significant requirements in 2025, and the continued addition of new PFAS to the Stockholm Convention means these restrictions are truly becoming global.
3. Supply Chain Disruptions & Product Obsolescence
Even without regulatory changes, PFAS availability is declining. Major chemical producers like 3M are phasing out PFAS production, and others are following quietly. As litigation and public pressure mount, PFAS materials and intermediates are disappearing from the market.
If you don’t know where PFAS chemicals exist in your products and processes, you could face sudden supply disruptions or product obsolescence. You can avoid these risks by proactively identifying PFAS in your supply chain. This allows for controlled phase-outs and redesigns and prevents you from having to make last-minute scrambles that impact production and profitability.
4. Market Expectations Are Rising
Consumer awareness of PFAS is growing, and brands are responding. Many companies now market PFAS-free products as a key selling point. Even if your organization isn’t required to report PFAS data to regulators, your customers may still demand it.
Distributors, suppliers, and manufacturers are increasingly expected to provide PFAS transparency alongside data for established regulations like REACH and the Restriction of Hazardous Substances (RoHS) Directive. Having PFAS information readily available isn’t just about compliance — it’s about maintaining business relationships and meeting customer expectations in a shifting marketplace.
5. Litigation & Financial Risk Are Growing
PFAS contamination has already led to billions in cleanup and settlement costs, and litigation continues to increase. Insurers and investors are watching closely, pushing companies to identify and mitigate PFAS risks before they become financial liabilities.
Being able to prove that your company does not use PFAS, or at least has an actionable plan to phase them out, will become a key part of maintaining trust and securing investment.
The Time to Act Is Now
TSCA Section 8(a)(7) is just one piece of legislation in an expanding global PFAS regulatory landscape. Organizations that pause their PFAS efforts in response to the EPA’s proposed exemptions risk falling behind competitors that continue to collect data, engage suppliers, and build transparency.
The message is clear: Even if you think you’re out of scope, PFAS due diligence is still critical. Acting now ensures your business stays compliant, competitive, and prepared for what comes next.
See how Assent’s PFAS solution can help you stay ahead of these risks. With data on more than five million parts, the solution is already helping companies meet emerging global requirements, from Canada’s PFAS reporting rule to upcoming EU restrictions.
