By John Kowalski
On October 11, 2023, the U.S. Environmental Protection Agency (EPA) published a final reporting and recordkeeping rule for Per- and polyfluoroalkyl substances (PFAS) under Section 8(a)(7) of the Toxic Substances Control Act (TSCA). The rule established a one-time reporting requirement for any entity that has manufactured or imported for commercial purposes at any time since 2011 a chemical substance, mixture, or article containing PFAS.
The rule does not include a list of specifically identified substances. Rather, it applies to PFAS as a chemical category defined by molecular structure. More specifically, the rule defines PFAS as any chemical substance or mixture containing a chemical substance that structurally contains at least one of the following three sub-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 rule requires reporting by entities that have manufactured PFAS or imported PFAS or articles containing PFAS between January 1, 2011, and December 31, 2022.
View the full article from the UL Solutions Regulatory expert team here.
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