Federal PFAS Reporting Deadline Extended as Biden Administration Announces New PFAS Strategic Plan
The White House revealed its latest strategy to address PFAS, and the EPA extended the reporting deadline for its PFAS reporting rule.
On September 5, 2024, the Environmental Protection Agency ("EPA") announced through a direct final rule an eight-month delay in the reporting and recordkeeping requirements for per- and polyfluoroalkyl substances ("PFAS") chemicals under the Toxic Substances Control Act. These requirements obligate any person who has manufactured or imported PFAS since 2011 to report their uses, production volumes, disposal, exposures, and hazards to EPA through an online portal. Though reporting was set to open November 12, 2024, and close May 8, 2025, this delay will shift reporting to open July 11, 2025, and close January 11, 2026. According to EPA, the delay is a result of budgetary constraints that delayed development of the reporting software.
This announcement came just two days after the Biden administration released a new PFAS Strategic Plan on September 3, 2024. This plan identifies the goals, objectives, and tasks for PFAS research and development across the federal government for the next five years. The strategies aim to:
- Understand PFAS exposure pathways to individuals and communities;
- Address current PFAS measurement challenges through the development of standards, advanced sampling, and analytical methodologies;
- Understand the toxicological mechanisms, human and environmental health effects, and risks of PFAS exposure;
- Develop, evaluate, and demonstrate technologies for the removal, destruction, and disposal of PFAS; and
- Identify PFAS alternatives and evaluate their human health and environmental effects.
This action builds off of the previous 2023 PFAS Strategy Team Report, which created four overarching goals for the federal PFAS strategy to drive federal research and development. The newly released plan identifies areas where further research is needed for short-and-long-term study to guide policymakers, indicating the federal government’s intention for further future PFAS regulation.
The strategic plan not only includes goals and guideposts, but also creates tasks for agencies to carry out. These tasks include a wide range of activities: from initiating studies examining PFAS co-exposure and potential interactions with microplastics, petroleum constituents, metals, pesticides, and pharmaceuticals; to instructing federal agencies to begin developing AI tools to predict and estimate PFAS movement in soil media.
Taken together, these actions continue to demonstrate the evolving nature of PFAS regulation at the federal level and the administrative reality of implementing those regulations.
