On Friday, July 25, RV Industry Association (RVIA) representatives Bill Erny, senior manager of regulatory affairs, and Chad Reece, chair of the government affairs committee, participated in a stakeholder meeting with the U.S. Environmental Protection Agency’s Office of Chemical Safety to discuss the federal PFAS reporting requirements under Toxic Substances Control Act section 8(a)(7).
The rule requires companies that manufactured PFAS, or articles containing PFAS (including importers of origin), between January 2011 and December 2022 to begin reporting product information into a public database starting in April 2026.
During the discussion, meeting participants highlighted the challenges with the retrospective reporting requirements, including the length of the lookback period and the significant volume of information requested. A particular concern raised during the meeting is the difficulty of obtaining detailed chemical composition data from global supply chains, especially from overseas suppliers who may not have historically tracked this type of information.
EPA officials shared that they are currently evaluating various aspects of the rule, including how imported articles will be treated, the working definition of PFAS, and the length of the lookback period. The agency is planning to publish a proposed rule as early as this fall requesting public input.
The RV Industry Association will continue to engage closely with EPA throughout this process to ensure that the unique challenges of the RV industry are well understood and considered in any future regulatory actions.
For more information, please contact Bill Erny at berny@rvia.org
