TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for PFAS “Final Rule” – UPDATED

By: Victoria Cross on November 28th, 2023

November 2023 Update

On November 6th, the EPA published TSCA Section 8(a)(7) Rule List of Chemicals regarding the reporting and recordkeeping requirements.  

The EPA defines PFAS to include at least one of these three structures:  

  • R-(CF2)-CF(R’)R”, where both the CF2 and CF moieties are saturated carbons;  
  • R-CF2OCF2-R’, where R and R’ can either be F, O, or saturated carbons.  
  • CF3C(CF3)R’R’’, where R’ and R” can either be F or saturated carbons. 

The EPA is providing a list of substances that meet this definition, gathered from the Inventory, Low-Volume Exemptions, and the CompTox Chemicals Dashboard. This list is available in the EPA Comptox Chemicals Dashboard.

The chemical list is subject to expansion or modification, and the current number of chemical substances is about 11409 chemicals.

The TSCA Inventory and LVE list about 1200 substances are available on The Public List of TSCA PFAS for 8(a)(7) Rule.



The Environmental Protection Agency (EPA) finalized reporting and recordkeeping requirements for Per- and Polyfluoroalkyl Substances (PFAS) data, to protect communities from these forever chemicals. 

The EPA will require anyone who has manufactured or imported PFAS or PFAS-containing articles since January 1, 2011, to report electronically on PFAS uses, production volumes, disposal, exposures, and hazards. Manufacturers will have 18 months from the effective date of November 13, 2023, to report PFAS data to the EPA. Small manufacturers, however, could have 24 months, depending on their reporting obligations.

The EPA maintains a list of all chemical substances manufactured, processed, or imported in the United States called the TSCA Chemical Substance Inventory. This list includes over 1,460 PFASs. This new ruling enables EPA to better characterize the sources and quantities of manufactured PFAS in the United States. 

How This Impacts Manufacturers 

This new ruling enables the EPA to better gather actionable data on ‘forever chemicals’. By collecting this new data, the EPA, as well as state and local governments, can enact new policies and regulations that may impact manufacturers that have products containing PFAS articles. 

How Can SiliconExpert Help?

With the continued evolution of PFAS and other chemical regulations, SiliconExpert maintains up-to-date- compliance data to support our customers through these changing regulations to better serve our customers. At this time, the P5 Platform Compliance Data incorporates PFAS substances through REACH, PFOA, PFOS, and POPs. 




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