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EPA Extends Toxic Substances Control Act Reporting Deadline

EPA

On Sept. 5, the U.S. Environmental Protection Agency (EPA) announced that the reporting period for PFAS under the Toxic Substances Control Act (TSCA) Section 8(a)(7) would be delayed to July 11, 2025, through Jan. 11, 2026.

Originally scheduled for Nov. 12 to May 8, 2025, the new extension allows businesses more time to comply with the requirements for reporting per- and polyfluoroalkyl substances (PFAS)​. To read the technical correction, click here.

Per- and Polyfluoroalkyl Substances (PFAS), also known as “forever chemicals,” are a class of man-made chemicals used in countless consumer products that are most known for their material properties such as resistance to water, oil, friction and increased durability. The strong carbon-fluorine bonds of PFAS make some of them resistant to degradation and thus highly persistent in the environment. Some of these chemicals have been used for decades in a wide variety of consumer and industrial products. Products used within the RV industry that may contain PFAS, include but are not limited to textile articles, carpets, rugs, fabric treatment, furnishings, upholstery, flame retardants, adhesives, solar components and semiconductors.

In October 2023, the EPA finalized the Toxic Substances Control Act Section 8(a)(7) Reporting and Record Keeping Rule, which mandates the reporting of PFAS by the manufacturers or importers of PFAS or PFAS-containing articles in any year since Jan. 1, 2011.

The RV industry encourages our members to continue working diligently toward compliance with the EPA’s TSCA Section 8(a)(7) Reporting and Record Keeping Rule. This includes working to obtain material disclosures from your supply chain, dating back to Jan. 1, 2011. By ensuring transparency and gathering detailed information on PFAS in materials, manufacturers can better align with federal regulations while also preparing for the upcoming extended reporting deadline. It is essential that members engage their suppliers to provide accurate, historical data to help meet these standards and avoid potential compliance issues.

The RV Industry Association’s Government Affairs Team created a Resources Hub on PFAS issues at both the Federal and State levels. The Hub includes one-pagers, articles, and a legislative tracker to help you stay informed about the latest PFAS developments and news.

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