May 20, 2025 PFAS Reporting & Risks: The Countdown Is On

With fewer than 100 days before the EPA’s PFAS reporting window opens, manufacturers must act now to avoid disruptions and fines.

By Cally Edgren, Vice President, Regulatory & Sustainability, Assent

Manufacturing has reached a critical juncture when it comes to per- and polyfluoroalkyl substances (PFAS). There are now fewer than 100 days until the Environmental Protection Agency (EPA) opens the submission period for PFAS reporting under Toxic Substances Control Act (TSCA) Section 8(a)(7), requiring data from 2011 to 2022. The shift away from using and manufacturing products is no longer a distant industry concern but an immediate business reality.

Businesses cannot afford to delay taking action, as failing to act can result in supply chain disruptions, legal penalties, and reputational damage. Instead, proactive compliance creates an opportunity to future-proof operations and gain a competitive edge.

A Race Against the Clock

Under TSCA, all businesses that have manufactured or imported PFAS in any year between 2011 and 2022, including if the PFAS is already incorporated into a product, must electronically submit data to the EPA’s Central Data Exchange platform. Once the submission window opens on July 11, 2025, companies will have six months (until January 11, 2026) to submit all required data. Small manufacturers may qualify for an additional six-month extension.

That sounds like a lot of time to report, but it isn’t. If you’re in scope, you can’t afford to wait.

Over 1,400 substances on the TSCA inventory are estimated to meet the reporting criteria. The EPA and other regulators with upcoming reporting rules recommend, among other strategies, collecting data from suppliers. But it can take months to identify PFAS in complex supply chains and share all that data across multiple supplier links. Companies that treat the submission window opening as the starting gun will find themselves scrambling to reach the finish line — and they’ll fall far behind competitors that already have their data ready for submission.

The time to start preparing was in 2023, when the new rule was published. But for companies that didn’t take action, today is the second-best time to start. To get all their supply chain due diligence done on time, companies should use a programmatic approach or AI tools that eliminate as much manual labor as possible.

The Tip of the PFAS Iceberg

Non-compliance with TSCA reporting isn’t the only PFAS risk manufacturers face. Companies also need to understand how global laws will affect their market access.

Several jurisdictions, especially U.S. states and countries that are part of the Stockholm Convention, have already enacted PFAS bans, restricted PFAS in certain product categories, and/or implemented disclosure requirements. Many others have proposed legislation that is expected to come into effect soon.

Litigation liability is also escalating: Since 2005, more than 6,400 PFAS-related lawsuits have been filed. In 2023 alone, U.S. PFAS settlements exceeded $10 billion USD. Downstream companies that use but do not manufacture PFAS chemicals are facing legal action too. No wonder chemical companies like 3M are discontinuing PFAS manufacturing, to minimize their risk exposure.

The ripple effect will be felt across entire industries. Over 22,000 3M products are being phased out by the end of 2025, and that’s only the beginning. Many smaller manufacturers are also ceasing PFAS production with less fanfare, so companies can’t simply switch suppliers and expect the same access to parts. As PFAS manufacturing slows down, supply chains will face disruption, and companies will need to deal with unplanned parts obsolescence. Now is the time to identify PFAS-free alternative parts and secure last-time buys for critical components.

What to Consider When Making Substitutions

Not all PFAS are created equal! Knowing which specific PFAS are in your products is key to determining the urgency of replacing them. For example, if a highly restricted substance like PFOA is present, it might be higher on the priority list for redesign versus more commonly used fluoropolymers like PTFE.

Many PFAS applications already have viable substitutions for the same application. For example, waterproofing footwear may be done with silicone. However, other applications may not be as easy to replace. This information is also important for manufacturers who want to engage with regulators to advocate for currently unavoidable use exemptions in various state PFAS laws.

Keep in mind, when PFAS are replaced with a product, the new materials may not perform the same way. PFAS are known for durability, and parts containing alternate substances may not last as long. This can reduce the product’s ultimate performance and life expectancy, which in turn may require a company to adjust warranties and service agreements. This can also impact parts used in manufacturing operations, driving more frequent maintenance and repair activities. Changes in parts can also impact product certifications, requiring investment in testing and requalifying products for market.

PFAS by the Numbers

PFAS are everywhere. They are used so broadly, it’s difficult to imagine any manufacturer that isn’t touched by PFAS regulations or parts obsolescence. In our research on PFAS in manufacturing supply chains, Assent has collected over 4 million PFAS declarations from suppliers around the globe, and the data speaks volumes:

• 82% of our customers identified PFAS in their supply chains
• 75% of the declarations with PFAS are for the same substances used in products on the 3M discontinuation list, which could accelerate obsolescence
• 50% of PFAS declarations are for, or include, polytetrafluoroethylene (PTFE), more commonly known by one of its commercial names, Teflon

This points to the reality that most manufacturers have some PFAS risk in their supply chain, even if it’s just for materials used for maintenance, repair, or machine operation that don’t make it into their final products — think O-rings and gaskets.

This Is Your Signal to Act

Companies can no longer wait and see if TSCA changes (there are hundreds of other PFAS regulations) or if the deadline for reporting will change (there are many laws now requiring reporting). If you don’t already have a PFAS compliance program actively collecting supplier data, you are behind — and catching up will require immediate, decisive action. If you haven’t started yet, this is an emergency.

Here’s what to do:

• Engage your suppliers immediately to educate them on reporting obligations and secure PFAS declarations
• Build cross-functional collaboration within your organization by ensuring procurement, compliance, engineering, and legal teams are aligned on PFAS reporting strategies. Avoiding non-compliance penalties and upset customers requires a coordinated effort
• Give suppliers a secure digital portal for data submissions instead of confusing spreadsheets
• Eliminate unnecessary manual data collection. Use a platform approach and an AI-enhanced solution to automate supplier outreach so you can spend the little remaining time on meeting your compliance requirements
• Start identifying PFAS-free alternatives and secure them now. Don’t wait until your supplier discontinues PFAS production to start sourcing parts. By then, competition among those who haven’t redesigned may be fierce and prices will be through the roof. Coordinating last-time buys takes time, money, and warehouse space
• Identify products affected by potential PFAS restrictions. Will you need to redesign them, and possibly begin a lengthy recertification process? Or will the product be retired early? How will you manage reduced life expectancy and spare part requirements? These are big decisions that your organization will need to make with the data you collect

Overwhelmed? Don’t be — but do take action now. Assent has more resources and education to help you and your suppliers to manage your PFAS risk. Visit assent.com to learn more and get started.

Note: All dates in this article are current as of April 30, 2025.

About the Author:
Cally Edgren has over 30 years of experience working at global manufacturers, including Rockwell Automation, Kohler Co., and Rayovac. She now leads a team of regulatory experts at Assent, a supply-chain sustainability software provider, as the Vice President of Regulatory & Sustainability. She’s known for her expertise in product materials regulations, market access certifications, and supply chain sustainability initiatives. In recent years, she’s been recognized as an industry-leading expert on PFAS regulations and has appeared on Bloomberg, FINTECH, and Scripps, among other prominent media outlets. Cally graduated from the University of Wisconsin with degrees in industrial engineering and enjoys developing programs, systems, and processes to create and qualify safe, compliant products. She’s passionate about product compliance and helping manufacturers build strong partnerships with their suppliers to support their market requirements.

Read more from the author:

Avoiding Disruptions with Supply Chain Sustainability | Industry Today, November 3, 2022

Planning for 2024 Regulatory Compliance | Industry Today, September 18, 2023

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