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Fifteen U.S. state attorneys general have submitted comments to the U.S. Environmental Protection Agency (EPA), expressing their opposition to a proposed revision to PFAS reporting policy under the Toxic Substances Control Act (TSCA).
The comments were submitted Dec. 22 by attorneys general of Connecticut, Illinois, California, Hawaii, Maryland, Massachusetts, Michigan, Minnesota, New Jersey, New York, North Carolina, Oregon, Rhode Island, Washington and Wisconsin.
The TSCA requires manufacturers and importers of PFAS between 2011–2022 to report certain data to the EPA related to exposure and environmental and health effects. The EPA’s proposed revision, which was announced in November 2025, incorporates certain exemptions and other changes to the scope of the reporting requirement. The proposal was open for public comment through Dec. 29. To read the proposed rule, visit regulations.gov/document/EPA-HQ-OPPT-2020-0549-0311.
“Under the Proposal, EPA would adopt reporting exemptions that would consume the Reporting Rule, exemptions that the Agency specifically considered and rejected when it issued the current, well-supported Reporting Rule just two years ago. EPA’s Proposal marks a complete, unsupported, and unsupportable reversal by the Agency on whether to acquire robust PFAS data under TSCA section 8(a)(7), 15 U.S.C. § 2607(a)(7),” states the document. “In effect, the Proposal would gut the Reporting Rule—by adding exemptions which effectively would reduce the number of responding entities by over 98 percent—and thus impede important data collection. This data is necessary for EPA to evaluate and manage the risks associated with PFAS exposure and to prevent harm to human health and the environment. Additionally, this crucial data is also valuable to our States and the public.”
To read the state attorneys general’s submitted comments, click here.