PFAS Reporting Is Here: What TSCA 8(a)(7) Means for 2025–2026

Frequently Asked Questions

Does TSCA 8(a)(7) apply if we only import finished goods or parts that may contain PFAS?

It can. The post explains that importing under TSCA can include importing articles that contain PFAS, so finished goods, components, packaging, textiles, electronics, and similar items may need review.

Who inside the company should be involved in PFAS reporting preparation?

The post says EHS should not handle TSCA 8(a)(7) alone. Legal, procurement, supply chain, product stewardship, quality, operations, and customs or trade compliance may all hold records or decisions needed for a complete review.

Why should we contact suppliers before the reporting window opens?

Supplier outreach can take time because vendors may need to research historical formulations, archived specifications, or article-level PFAS content that does not appear on standard SDSs. Starting early also helps avoid conflicting requests from different internal teams.

What records should we start collecting now for TSCA 8(a)(7)?

The post recommends gathering import and customs data, bills of material, product specifications, purchasing histories, supplier declarations, formulation records, quality documents, engineering change notices, and contracts or private-label agreements. It also suggests sorting products into simple categories such as likely PFAS, unlikely PFAS, needs supplier confirmation, and incomplete records.

What should EHS leaders do in 2025 to get ready for 2026 PFAS reporting?

The post recommends treating 2025 as preparation time by confirming whether the business manufactured or imported PFAS or imported articles that may contain PFAS. EHS can help form a cross-functional workgroup, organize records, launch supplier outreach, track data gaps, and document the decision process.