TSCA 8(a)(7) Rule Q&A with 3E: TSCA PFAS Supply Chain Data Collection, PFAS Screening, and PFAS Reporting Tools

Note: As of May 2025, the U.S. EPA has extended reporting deadlines under TSCA 8(a)(7). Most reporters would be required to complete all reporting my October 13, 2026. Small businesses reporting data solely on importing PFAS contained in articles will have until April 13, 2027 to submit reports.

It seems like PFAS are everywhere- in the air, in drinking water, and accumulating in the environment. This persistence not only harms the environment but also negatively affects human health.

In response to the dangers of PFAS, the U.S. EPA finalized a new PFAS reporting rule under Section 8(a)(7). Companies that currently manufacture and/or import (or have manufactured and/or imported) products containing PFAS must electronically report on “PFAS uses, production volumes, byproducts, disposal, exposures, and existing information on environmental or health effects” from January 1, 2011 forward (88 FR 70516; see the Federal Register).

Question/Answer 

Below you will find a series of questions that might come to mind when complying with this new rule.

Question: Do I really have to dig through records from 13 years ago?  

Answer: Yes, you do. Note that the regulation applies to any year starting from 2011. Even if you only used PFAS in your products for one of those years, you are responsible for reporting information to the U.S. EPA.

Question: How do I collect the necessary data? 

Answer: 3E Exchange has pre-built survey templates for TSCA 8(a)(7) that already includes everything you need to ask your suppliers.  User-friendly workflows make it easy to deliver, track, and collect supplier surveys with audit trails.  It’s free, so your suppliers can use these tools themselves to collect the same data from the entire supply chain.

Question: How do I know what to report?  

Answer: 40 CFR Part 705.15 includes details about what to report and refers to this particular reporting obligation as a one-time submission.

1. Main categories include:
2. Company and plant site
3. Chemical specific information
4. Categories of use
5. Manufactured amounts
6. Byproduct[s]
7. Environmental and health effects
8. Worker exposure data
9. Disposal data

Question: Where can I find instructions from EPA?  

Answer: EPA has outlined FAQs and guidance on their website: TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances

Question: How do I handle my supplier relationships? 

Answer: It is likely that you will need to have a steady stream of communication with your suppliers to ascertain: 1) if the rule applies to them and 2) what responsibilities you have (what you need to report) based on supplier PFAS use.

This final Q/A is quite complex. You need to account for your own PFAS use and uses in every step of your supply chain.

3E's NEW TSCA 8(a)(7) Supply Chain Questionnaire  

3E Exchange's newly released TSCA 8(a)(7) supply chain questionnaire and reporting template enables you to manage supplier data collection to meet this reporting requirement.

Our TSCA 8(a)(7) supply chain questionnaire is the only FREE tool on the market for streamlined supply chain data collection. Using this questionnaire, you may create TSCA 8(a)(7) specific surveys for your suppliers and once you have their responses, generate branded reports directly in the 3E Exchange platform.

Asking the right questions at the beginning of the information collection process is key for compliance, as is getting responses from suppliers in a timely fashion. In addition to TSCA, 3E Exchange enables supply chain data collection and compliance tracking for most major regulatory frameworks.

See more from 3E experts on TSCA 8(a)(7) PFAS Reporting.

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