EPA PFAS Reporting Deadline: The October 13, 2026 Window Never Opened, and the Start Is Now No Later Than January 31, 2027

Correction to an outdated date: the EPA PFAS reporting window that was due to close on October 13, 2026 never opened. In a final rule published in the Federal Register on April 13, 2026, EPA moved the start of the submission period to January 31, 2027, or 60 days after a forthcoming substantive final rule takes effect, whichever is earlier. As of October 15, 2026, there is no October 13 deadline to have missed.

The old April 13 to October 13, 2026 dates came from the May 2025 interim final rule, which the April 2026 rule overtook. This article sets out who is covered, what changed, and what happens next, using EPA and Federal Register documents.

Did the EPA PFAS reporting window close on October 13, 2026?

No. The window never opened, because EPA changed the start date before April 13, 2026 arrived. The Federal Register notice says the rule is effective April 13, 2026, the same day it was published.

EPA announced the change on April 9, 2026. Its release says the action moves the start of the reporting period from April 13, 2026 to 60 days after the effective date of the agency's forthcoming revision to the rule.

The earlier dates came from a May 2025 interim final rule. EPA's May 12, 2025 release said submissions would be due by October 13, 2026 for most manufacturers, and by April 13, 2027 for small manufacturers reporting exclusively as article importers. Those dates were the codified ones until the April 2026 rule replaced the start date.

What is the new EPA PFAS reporting deadline?

There is no fixed end date yet. The submission period begins on January 31, 2027, or 60 days after the effective date of EPA's forthcoming final rule on the substantive requirements, whichever is earlier, according to the Federal Register. The end date depends on the duration EPA sets in that later rule.

EPA did not change the length of the period in the April 2026 action. The rule keeps the codified six-month period, with an additional six months for small manufacturers whose reporting obligations come only from article import. EPA says it will address changes to the duration in its forthcoming final action.

A simple calculation shows how the two start dates interact. Sixty days before January 31, 2027 is December 2, 2026. If the substantive rule takes effect before that date, the 60-day path gives an earlier start than the backstop. If it takes effect later, January 31, 2027 governs. This is our arithmetic, not an EPA statement.

How did the PFAS reporting date keep moving?

The start date has moved three times since the October 2023 rule, each time because of reporting tool delays or the need to review public comments. The Federal Register notice lays out the sequence.

Source: Federal Register, 91 FR 18786, as published April 13, 2026.

Who must report PFAS under TSCA section 8(a)(7)?

Anyone who has manufactured, including imported, PFAS for a commercial purpose at any time since January 1, 2011. That wording comes from the Federal Register notice. EPA's rule page adds that the 2023 rule covers PFAS-containing articles, so importers of finished goods are in scope under the current text.

EPA gives an illustrative, non-exhaustive list of sectors by NAICS code:

EPA points readers to the applicability criteria in 40 CFR 705.10 and 705.12 and says other types of entities not on the list could also be regulated. Companies unsure of their status are directed to the EPA contact named in the notice.

EPA's release describes the covered period as any year between 2011 and 2022. The data requested includes chemical identity, uses, volumes made and processed, byproducts, environmental and health effects, worker exposure and disposal. Reports go through EPA's Central Data Exchange.

What counts as PFAS under the rule?

EPA defines PFAS for this rule as a chemical substance containing at least one of three structures. EPA's rule page lists them as R-(CF2)-CF(R')R'', R-CF2OCF2-R', and CF3C(CF3)R'R'', with defined limits on what the R groups can be.

The same page says EPA had identified at least 1,462 PFAS covered by TSCA that may fall under the rule as of February 2023. Of those, 770 were on the active TSCA Inventory, meaning they are in U.S. commerce. Because the definition is structural, a company may hold substances that do not carry an obvious "PFAS" label.

Which exemptions has EPA proposed, and are they final?

None are final. The exemptions below were proposed in November 2025, and EPA's rule page lists them as proposals. The comment period ended on December 29, 2025.

Source: EPA's rule page, last modified April 16, 2026. The same list is described by Bergeson & Campbell, a law firm that tracks TSCA.

EPA's April 2026 rule says it will decide in the later final action whether to include any exemptions. It expects to finalize the revisions rule "regardless of whether EPA ultimately decides to finalize all, some, or none" of the proposed changes. Companies should not assume an exemption applies until a final rule says so.

Why did EPA delay the start again?

EPA says it needs time for public comments and for its tools. The Federal Register notice reports 27 unique comments and 639 mail-in campaign comments on the May 2025 interim final rule. On the November 2025 proposal, it reports nearly 600 unique comments and more than 8,500 comments from two mail-in campaigns.

EPA says it needs additional time to address these comments, write and publish a final rule, release updated guidance, and update its reporting tool. In its April 9, 2026 release, EPA said it wants a rule that delivers actionable reporting guidance "without unnecessary loopholes". The agency also said it plans to issue a final rule later this year. These are EPA's own stated reasons.

The notice records a split among commenters. Requests for how long to delay ranged from five months to five years after the substantive final action. A minority opposed any further delay, out of concern that it may slow data collection and public health protections.

What should manufacturers and importers do now?

The documents do not prescribe compliance steps, so this section sticks to what the filings imply. EPA's notice says the later start gives stakeholders time to plan for compliance and complete due diligence, and to avoid effort that may not match the final requirements.

• Keep the existing scope in view. Until a final rule changes it, the codified rule applies to PFAS and PFAS-containing articles manufactured or imported since 2011.
• Watch for the substantive final rule. Its effective date sets the 60-day clock, and it will decide exemptions and the length of the submission period.
• Track the January 31, 2027 backstop. EPA says the start will not be later than that date.
• Note the small-importer carve-out. Small manufacturers reporting solely as article importers get six additional months under the codified duration, but EPA may revisit duration.

The April 2026 rule is classed by EPA as a deregulatory action under Executive Order 14192. It says it creates no new reporting or recordkeeping obligations.

What's still unclear?

Several points remain open as of October 15, 2026.

• The substantive final rule. EPA's rule page, last modified April 16, 2026, lists the April 2026 action as its latest update and says a final rule is expected in 2026. EPA's April 9 release said it planned to issue one "later this year." EPA's pages give no effective date for it.
• Submission period length. The rule keeps six months, but the November 2025 proposal would have the period last three months, according to Bergeson & Campbell. EPA has deferred this decision.
• Which exemptions survive. EPA has said it may finalize all, some or none of them. The imported-articles exemption matters most to importers of finished goods.
• Judicial review. EPA says the two start dates are severable: if a court vacated one, the other would stay in place. The notice cites no pending case.
• Source conflicts. Guidance published before April 2026 shows October 13, 2026 as the deadline. That date was superseded. The Federal Register and EPA pages are the controlling sources.

The weakest point of any compliance plan built on the old date is simple: the date no longer exists. The weakest point of a plan built on the proposed exemptions is that they are not law.