BRIEF: EPA’s TSCA Section 8(a)(7) PFAS reporting rule now requires manufacturers and importers to begin reporting on April 13, 2026. The rule demands detailed, “reasonably ascertainable” data across uses, volumes, byproducts, exposure, and disposal. At the same time, attention is expanding to persistent degradation products like TFA. Together, these forces are pushing PFAS beyond compliance into transparency and risk management. Companies that organize product data now will be better positioned as deadlines—and scrutiny—approach.
PFAS oversight has become less linear and more unsettled. EPA’s TSCA Section 8(a)(7) reporting rule was designed to bring structure to how PFAS have been manufactured and used, but recent extensions and clarifications reflect how complex that task has proven to be in practice. For most manufacturers and importers, reporting begins April 13, 2026.
In November 2025, the EPA proposed changes to the scope of TSCA 8(a)(7) PFAS reporting regulations. Read the Federal Register Notice.
The scope of what must be reported is broad. Companies are expected to submit information that is known to or reasonably ascertainable. This includes chemical identity, uses, production volumes, byproducts, worker exposure, disposal practices, and any available health or environmental data. Reporting must be completed electronically through EPA’s CDX system, which places additional emphasis on data readiness and internal coordination well before the submission window opens.
At the same time, the conversation is moving beyond familiar PFAS compounds. Trifluoroacetic acid (TFA) has appeared with increasing frequency in global water studies. It is not broadly regulated in the United States, but its prevalence has prompted questions about long-term environmental behavior and whether existing oversight frameworks are keeping pace with emerging science.
For manufacturers, this moment is less about compliance checklists and more about preparedness. Customers ask different questions than they did even a few years ago. They want to know what materials are present, how those materials persist, and what happens downstream. PFAS has shifted from a narrow regulatory topic to a broader transparency issue, touching procurement, product stewardship, and executive risk discussions—often well before regulators knock.
For customers paying closer attention to PFAS and emerging contaminants, Brainerd Chemical’s product portfolio reflects a practical advantage grounded in formulation discipline and documentation. The company emphasizes chemistries that meet performance needs without introducing unnecessary persistence concerns, supported by clear product data and traceability. In applications such as water treatment, sanitation, and industrial processing, this approach gives customers better visibility into what they are using and why—an increasingly important factor as reporting deadlines approach and expectations continue to sharpen.
Why this has become a board-level issue
The April 2026 reporting start date may seem distant, but the data required spans more than a decade of activity. Customers, auditors, and regulators are already pressing for clarity around inputs, intermediates, and byproducts—often earlier in the sourcing process.
PFAS compliance is no longer viewed solely as a regulatory requirement. It has become a measure of credibility—tied to how clearly a company understands its products, how well it documents them, and how confidently it can explain both today and five years from now.
Looking ahead
As the April 2026 reporting deadline approaches, the difference between manageable compliance and a costly scramble will come down to preparation. For many customers, Brainerd Chemical plays a quiet but important role in that process by reducing uncertainty early—through clear product documentation, consistent data, and chemistries designed with stewardship in mind. When suppliers can answer questions clearly, customers spend less time chasing historical data, reconciling gaps, or responding under pressure. That clarity doesn’t just support compliance; it saves time, limits disruption, and helps prevent the kind of last-minute reporting issues that turn regulatory obligations into operational crises.
