PFAS Disclosure — Regulatory Updates https://pfasdisclosure.com/updates Reverse-chronological log of PFAS regulatory changes across all 50 U.S. states and federal EPA. Primary source citations on every entry. Covers state product bans, reporting deadlines, federal TSCA rulemaking, and enforcement updates. Built by Howard Orloff — pfasdisclosure.com. en-us Tue, 12 May 2026 00:00:00 +0000 Tue, 12 May 2026 00:00:00 +0000 howard@howardorloff.net (Howard Orloff) howard@howardorloff.net (Howard Orloff) 2026 PFAS Disclosure — pfasdisclosure.com. Built by Howard Orloff (howardorloff.net). https://www.rssboard.org/rss-specification Regulatory Compliance PFAS Environmental Law 1440 https://pfasdisclosure.com/favicon.svg PFAS Disclosure https://pfasdisclosure.com EPA (Federal) — TSCA §8(a)(7) October 2026 deadline confirmed unaffected by drinking water reconsideration https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/pfas-reporting-and-recordkeeping-requirements https://pfasdisclosure.com/updates#2026-05-003 Tue, 12 May 2026 00:00:00 +0000 Howard Orloff Federal EPA TSCA Deadline Clarification EPA has confirmed that the TSCA Section 8(a)(7) PFAS reporting deadline of October 26, 2026 for most manufacturers and importers is not affected by the agency's reconsideration of the 2024 National Primary Drinking Water Regulation (NPDWR). The two programs operate under separate statutes — TSCA and the Safe Drinking Water Act (SDWA) — administered by separate EPA offices.

Impact: High

Statute: TSCA §8(a)(7) — 40 C.F.R. Part 705

Key deadline (unchanged): October 26, 2026 (most reporters); April 13, 2027 (small manufacturers as article importers)

Source: EPA TSCA PFAS Reporting Program — epa.gov

Verified: May 2026

This entry provides compliance information for reference only and does not constitute legal advice.

]]> EPA has confirmed that the TSCA Section 8(a)(7) PFAS reporting deadline of October 26, 2026 for most manufacturers and importers is not affected by the agency's reconsideration of the 2024 National Primary Drinking Water Regulation (NPDWR). The two programs operate under separate statutes — TSCA and the Safe Drinking Water Act (SDWA) — administered by separate EPA offices. A change to drinking water MCLs has no procedural or legal effect on TSCA reporting obligations.

  • Primary deadline (unchanged): October 26, 2026
  • Extended deadline (small manufacturers as article importers, unchanged): April 13, 2027
  • Statute: TSCA §8(a)(7) — 40 C.F.R. Part 705
  • Agency: U.S. Environmental Protection Agency (EPA) — Office of Chemical Safety and Pollution Prevention (OCSPP)
  • Jurisdiction: Federal

Small manufacturers qualifying as article importers retain the April 13, 2027 extended deadline. No rulemaking to alter the TSCA deadline had been announced as of May 2026. State deadlines — including Minnesota PRISM (September 15, 2026) — are also unaffected.

Source: EPA TSCA PFAS Reporting Program — epa.gov · Verified May 2026

Full federal guide: pfasdisclosure.com/federal

TSCA vs drinking water comparison: pfasdisclosure.com/federal/tsca-vs-drinking-water

State laws unaffected: pfasdisclosure.com/federal/state-laws-and-federal-delay

Disclaimer: This entry provides compliance information for reference only and does not constitute legal advice. Always verify current requirements with the relevant state agency or qualified legal counsel.

]]> EPA (Federal) — EPA signals PFOA and PFOS MCLs may be retained during NPDWR reconsideration https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations https://pfasdisclosure.com/updates#2026-05-002 Thu, 07 May 2026 00:00:00 +0000 Howard Orloff Federal EPA PFOA PFOS MCL NPDWR EPA has publicly indicated that Maximum Contaminant Levels (MCLs) for PFOA (4 ppt) and PFOS (4 ppt) may be retained during the agency's reconsideration of the 2024 National Primary Drinking Water Regulation. The reconsideration appears focused on PFNA, PFHxS, HFPO-DA/GenX, and PFBS — not PFOA and PFOS.

Impact: High

Chemicals that may be retained: PFOA (4 ppt), PFOS (4 ppt)

Chemicals under active review: PFNA (10 ppt), PFHxS (10 ppt), HFPO-DA/GenX (10 ppt), PFBS (Hazard Index)

Source: EPA Safe Drinking Water Act — NPDWR for PFAS (April 2024)

Verified: May 2026

This entry provides compliance information for reference only and does not constitute legal advice.

]]> EPA has publicly indicated that Maximum Contaminant Levels (MCLs) for PFOA (4 ppt) and PFOS (4 ppt) — the two longest-studied and most widely detected PFAS — may be retained during the agency's reconsideration of the 2024 National Primary Drinking Water Regulation. The agency's public statements suggest the reconsideration is focused on the MCLs for PFNA, PFHxS, HFPO-DA/GenX chemicals, and the Hazard Index limit for PFBS-containing mixtures.

  • MCLs signaled for retention: PFOA (4 ppt), PFOS (4 ppt)
  • MCLs under active reconsideration: PFNA (10 ppt), PFHxS (10 ppt), HFPO-DA/GenX (10 ppt), PFBS (Hazard Index ≤ 1)
  • No final rule issued: As of May 2026, no final rule confirming retention or revocation of any MCL had been issued
  • CERCLA status: PFOA and PFOS remain CERCLA hazardous substances regardless of drinking water MCL status
  • Agency: U.S. Environmental Protection Agency (EPA)
  • Jurisdiction: Federal

Source: EPA Safe Drinking Water Act — National Primary Drinking Water Regulations for PFAS (April 2024) · Verified May 2026

EPA Rollback explainer: pfasdisclosure.com/federal/pfas-drinking-water-rollback

Chemical profiles — PFOA, PFOS, PFNA, PFHxS, GenX, PFBS: pfasdisclosure.com/federal/pfas-chemicals-rollback

Disclaimer: This entry provides compliance information for reference only and does not constitute legal advice. Always verify current requirements with the relevant state agency or qualified legal counsel.

]]> EPA (Federal) — EPA announces reconsideration of 2024 PFAS NPDWR — PFNA, PFHxS, GenX, PFBS MCLs under review https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations https://pfasdisclosure.com/updates#2026-05-001 Fri, 01 May 2026 00:00:00 +0000 Howard Orloff Federal EPA NPDWR Reconsideration PFNA PFHxS GenX PFBS EPA announced it will reconsider aspects of the April 2024 National Primary Drinking Water Regulation (NPDWR) for PFAS. The reconsideration focuses on MCLs for PFNA (10 ppt), PFHxS (10 ppt), HFPO-DA/GenX chemicals (10 ppt), and the Hazard Index limit for PFBS-containing mixtures. The reconsideration applies exclusively to the SDWA drinking water program — it has no effect on TSCA §8(a)(7) reporting obligations or state PFAS product laws.

Impact: High

Statute: Safe Drinking Water Act (SDWA) — 40 C.F.R. Part 141

Source: EPA Safe Drinking Water Act — NPDWR for PFAS (April 2024)

Verified: May 2026

This entry provides compliance information for reference only and does not constitute legal advice.

]]> EPA announced it will reconsider aspects of the April 2024 National Primary Drinking Water Regulation (NPDWR) for PFAS. The reconsideration focuses on MCLs for four compounds and compound groups: PFNA (perfluorononanoic acid, 10 ppt), PFHxS (perfluorohexane sulfonic acid, 10 ppt), HFPO-DA commonly known as GenX chemicals (10 ppt), and the Hazard Index limit for mixtures of PFNA, PFHxS, HFPO-DA, and PFBS.

  • MCLs under reconsideration: PFNA (10 ppt), PFHxS (10 ppt), HFPO-DA/GenX (10 ppt), PFBS (Hazard Index ≤ 1)
  • Governing statute: Safe Drinking Water Act (SDWA) — 40 C.F.R. Part 141
  • Regulatory basis: EPA authority as promulgating agency — separate administrative proceeding from the 2024 rule
  • Current MCL status: Until EPA issues a final rule amending or vacating specific MCLs, those MCLs remain in effect
  • TSCA §8(a)(7) deadline: Unaffected — October 26, 2026 remains in force
  • Minnesota PRISM deadline: Unaffected — September 15, 2026 remains in force
  • All state product law deadlines: Unaffected by this drinking water reconsideration
  • Agency: U.S. Environmental Protection Agency (EPA) — Office of Water
  • Jurisdiction: Federal (drinking water program only)

Source: EPA Safe Drinking Water Act — National Primary Drinking Water Regulations for PFAS (April 2024) · Verified May 2026

Full EPA Rollback explainer: pfasdisclosure.com/federal/pfas-drinking-water-rollback

TSCA vs Drinking Water comparison: pfasdisclosure.com/federal/tsca-vs-drinking-water

Why state laws are unaffected: pfasdisclosure.com/federal/state-laws-and-federal-delay

Chemical profiles — PFNA, PFHxS, GenX, PFBS: pfasdisclosure.com/federal/pfas-chemicals-rollback

Disclaimer: This entry provides compliance information for reference only and does not constitute legal advice. Always verify current requirements with the relevant state agency or qualified legal counsel.

]]> EPA (Federal) — EPA TSCA §8(a)(7) reporting deadline confirmed: October 26, 2026 https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/pfas-reporting-and-recordkeeping-requirements https://pfasdisclosure.com/updates#2026-04-001 Tue, 01 Apr 2026 00:00:00 +0000 Howard Orloff Federal EPA TSCA Deadline EPA has confirmed the TSCA Section 8(a)(7) PFAS reporting deadline of October 26, 2026 for most manufacturers and importers of PFAS and PFAS-containing articles. Small manufacturers qualifying as article importers have an extended deadline of April 13, 2027. The rule was issued as an interim final rule in May 2025.

Impact: High

Source: EPA TSCA PFAS Reporting Program — epa.gov

Verified: April 2026

This entry provides compliance information for reference only and does not constitute legal advice. Always verify current requirements with the relevant state agency or qualified legal counsel.

]]> EPA has confirmed the TSCA Section 8(a)(7) PFAS reporting deadline of October 26, 2026 for most manufacturers and importers of PFAS and PFAS-containing articles. Small manufacturers qualifying as article importers have an extended deadline of April 13, 2027. The rule was issued as an interim final rule in May 2025.

  • Primary deadline: October 26, 2026
  • Extended deadline (small manufacturers as article importers): April 13, 2027
  • Statute: TSCA §8(a)(7) — 40 C.F.R. Part 705
  • Agency: U.S. Environmental Protection Agency (EPA)
  • Jurisdiction: Federal

Source: EPA TSCA PFAS Reporting Program — epa.gov · Verified April 2026

Full federal guide: pfasdisclosure.com/federal

Disclaimer: This entry provides compliance information for reference only and does not constitute legal advice. Always verify current requirements with the relevant state agency or qualified legal counsel.

]]> MPCA (Minnesota) — PRISM reporting deadline confirmed: September 15, 2026 https://www.pca.state.mn.us/pfas https://pfasdisclosure.com/updates#2026-03-001 Sun, 15 Mar 2026 00:00:00 +0000 Howard Orloff Minnesota MPCA PRISM Deadline The MPCA has confirmed that the PRISM annual reporting deadline for the 2025 reporting year is September 15, 2026. Manufacturers, importers, and distributors who sold products with intentionally added PFAS in Minnesota during 2025 must register with PRISM and submit their annual report by this date.

Impact: High

Source: Minnesota Pollution Control Agency — PRISM Portal

Statute: Minn. Stat. § 116.943 (Amara's Law)

Verified: April 2026

This entry provides compliance information for reference only and does not constitute legal advice.

]]> The MPCA has confirmed that the PRISM annual reporting deadline for the 2025 reporting year is September 15, 2026. Manufacturers, importers, and distributors who sold products with intentionally added PFAS in Minnesota during 2025 must register with PRISM and submit their annual report by this date. Late registration may result in late filing — contact MPCA if you have not yet registered.

  • Deadline: September 15, 2026
  • Statute: Minn. Stat. § 116.943 (Amara's Law)
  • Agency: Minnesota Pollution Control Agency (MPCA)
  • Portal: prism.pca.state.mn.us
  • Jurisdiction: Minnesota

Source: MPCA — pca.state.mn.us/pfas · Verified April 2026

Full state guide: pfasdisclosure.com/states/minnesota

Disclaimer: This entry provides compliance information for reference only and does not constitute legal advice. Always verify current requirements with MPCA or qualified legal counsel.

]]> CDPHE (Colorado) — Phase 2 PFAS product ban expanded — verify current scope https://cdphe.colorado.gov/pfas https://pfasdisclosure.com/updates#2025-12-001 Mon, 01 Dec 2025 00:00:00 +0000 Howard Orloff Colorado CDPHE Product Ban Colorado's PFAS Products Act (C.R.S. § 25-15-601) continues to phase in product bans. Additional product categories may have become subject to PFAS restrictions under Phase 2. Manufacturers and importers selling products in Colorado should verify the current scope of Colorado's product ban phase schedule with CDPHE.

Impact: Medium

Source: Colorado DPHE PFAS Products — cdphe.colorado.gov/pfas

Statute: C.R.S. § 25-15-601 (HB 22-1345)

Verified: April 2026

This entry provides compliance information for reference only and does not constitute legal advice.

]]> Colorado's PFAS Products Act (C.R.S. § 25-15-601) continues to phase in product bans. Additional product categories may have become subject to PFAS restrictions under Phase 2. Manufacturers and importers selling products in Colorado should verify the current scope of Colorado's product ban phase schedule with CDPHE at cdphe.colorado.gov/pfas.

  • Statute: C.R.S. § 25-15-601 (HB 22-1345)
  • Agency: Colorado Department of Public Health & Environment (CDPHE)
  • Jurisdiction: Colorado

Source: Colorado DPHE PFAS Products — cdphe.colorado.gov/pfas · Verified April 2026

Full state guide: pfasdisclosure.com/states/colorado

Disclaimer: This entry provides compliance information for reference only and does not constitute legal advice.

]]> EPA (Federal) — PFAS MCLs for drinking water finalized at 4 ppt for PFOA and PFOS https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations https://pfasdisclosure.com/updates#2025-10-001 Wed, 15 Oct 2025 00:00:00 +0000 Howard Orloff Federal EPA MCL Drinking Water EPA finalized Maximum Contaminant Levels (MCLs) for PFOA and PFOS in drinking water at 4 parts per trillion (ppt). While these MCLs apply to drinking water rather than products, they reflect the regulatory trajectory for PFAS and signal continued federal action. Manufacturers should monitor for EPA product-level regulations that may follow.

Impact: Medium

MCL: 4 ppt for PFOA, 4 ppt for PFOS

Source: EPA National Primary Drinking Water Regulations — epa.gov

Verified: April 2026

This entry provides compliance information for reference only and does not constitute legal advice.

]]> EPA finalized Maximum Contaminant Levels (MCLs) for PFOA and PFOS in drinking water at 4 parts per trillion (ppt). While these MCLs apply to drinking water rather than products, they reflect the regulatory trajectory for PFAS and signal continued federal action. Manufacturers should monitor for EPA product-level regulations that may follow.

  • MCL (PFOA): 4 ppt
  • MCL (PFOS): 4 ppt
  • Agency: U.S. Environmental Protection Agency (EPA)
  • Jurisdiction: Federal (drinking water systems)

Source: EPA National Primary Drinking Water Regulations — epa.gov · Verified April 2026

Glossary: MCL defined at pfasdisclosure.com/glossary

Disclaimer: This entry provides compliance information for reference only and does not constitute legal advice.

]]> DTSC (California) — AB 1817 textiles ban effective January 1, 2025 — enforcement ongoing https://dtsc.ca.gov/scp/pfas/ https://pfasdisclosure.com/updates#2025-07-001 Tue, 01 Jul 2025 00:00:00 +0000 Howard Orloff California DTSC Textiles AB 1817 California's AB 1817, which prohibits the sale of new textile articles containing regulated PFAS, became effective January 1, 2025. Manufacturers and importers selling textiles in California should verify compliance. DTSC enforcement is ongoing.

Impact: High

Statute: AB 1817

Effective: January 1, 2025

Source: California DTSC — dtsc.ca.gov

Verified: April 2026

This entry provides compliance information for reference only and does not constitute legal advice.

]]> California's AB 1817, which prohibits the sale of new textile articles containing regulated PFAS, became effective January 1, 2025. Manufacturers and importers selling textiles in California should verify compliance. DTSC enforcement is ongoing. Visit dtsc.ca.gov for current guidance.

  • Statute: AB 1817
  • Effective date: January 1, 2025
  • Agency: California Department of Toxic Substances Control (DTSC)
  • Jurisdiction: California

Source: California DTSC — dtsc.ca.gov/scp/pfas/ · Verified April 2026

Related category pages: Textiles & Apparel · Outdoor Apparel

Disclaimer: This entry provides compliance information for reference only and does not constitute legal advice.

]]> WA Ecology (Washington) — PFAS in Products phase schedule — verify current requirements https://ecology.wa.gov/pfas https://pfasdisclosure.com/updates#2025-06-001 Sun, 01 Jun 2025 00:00:00 +0000 Howard Orloff Washington WA Ecology Phase-In Washington's PFAS in Products law (RCW 70A.222) continues its phased implementation. Manufacturers and importers selling products in Washington should verify the current applicable phase and product categories at ecology.wa.gov/pfas.

Impact: Medium

Statute: RCW 70A.222 (SHB 2360)

Source: Washington State Department of Ecology — ecology.wa.gov/pfas

Verified: April 2026

This entry provides compliance information for reference only and does not constitute legal advice.

]]> Washington's PFAS in Products law (RCW 70A.222) continues its phased implementation. Manufacturers and importers selling products in Washington should verify the current applicable phase and product categories at ecology.wa.gov/pfas.

  • Statute: RCW 70A.222 (SHB 2360)
  • Agency: Washington State Department of Ecology
  • Jurisdiction: Washington

Source: Washington State Department of Ecology — ecology.wa.gov/pfas · Verified April 2026

Full state guide: pfasdisclosure.com/states/washington

Disclaimer: This entry provides compliance information for reference only and does not constitute legal advice.

]]> Maine DEP (Maine) — PFAS notification program ongoing — ban phase-in continues toward 2030 https://www.maine.gov/dep/spills/topics/pfas/ https://pfasdisclosure.com/updates#2025-01-001 Wed, 15 Jan 2025 00:00:00 +0000 Howard Orloff Maine Maine DEP CUU Notification Maine's PFAS in products law (38 M.R.S. § 1614) continues with mandatory notification requirements for products with intentionally added PFAS. The broader prohibition on PFAS products absent a currently unavoidable use (CUU) determination remains on track for January 1, 2030.

Impact: Medium

Statute: 38 M.R.S. § 1614

Key deadline: January 1, 2030 (broad product ban)

Source: Maine Department of Environmental Protection — maine.gov/dep

Verified: April 2026

This entry provides compliance information for reference only and does not constitute legal advice.

]]> Maine's PFAS in products law (38 M.R.S. § 1614) continues with mandatory notification requirements for products with intentionally added PFAS. The broader prohibition on PFAS products absent a currently unavoidable use (CUU) determination remains on track for January 1, 2030. Manufacturers should be actively notifying Maine DEP and assessing their CUU needs.

  • Statute: 38 M.R.S. § 1614
  • Agency: Maine Department of Environmental Protection (DEP)
  • Broad ban effective: January 1, 2030
  • Jurisdiction: Maine

Source: Maine DEP — maine.gov/dep/spills/topics/pfas/ · Verified April 2026

Full state guide: pfasdisclosure.com/states/maine

Glossary: CUU defined at pfasdisclosure.com/glossary

Disclaimer: This entry provides compliance information for reference only and does not constitute legal advice.

]]> MPCA (Minnesota) — 2024 PRISM reporting cycle complete — 2025 cycle now active https://prism.pca.state.mn.us https://pfasdisclosure.com/updates#2024-09-001 Sun, 15 Sep 2024 00:00:00 +0000 Howard Orloff Minnesota MPCA PRISM Reporting Cycle MPCA completed the 2024 PRISM reporting cycle (for the 2023 reporting year). The 2025 reporting cycle (covering calendar year 2024 products sold in Minnesota) was open. The next reporting deadline is September 15, 2026. Manufacturers who have not yet registered with PRISM should do so immediately.

Impact: High

Statute: Minn. Stat. § 116.943 (Amara's Law)

Next deadline: September 15, 2026

Source: MPCA PRISM Portal — prism.pca.state.mn.us

Verified: April 2026

This entry provides compliance information for reference only and does not constitute legal advice.

]]> MPCA completed the 2024 PRISM reporting cycle (for the 2023 reporting year). The 2025 reporting cycle (covering calendar year 2024 products sold in Minnesota) was open. The next reporting deadline is September 15, 2026. Manufacturers who have not yet registered with PRISM should do so immediately at prism.pca.state.mn.us.

  • Statute: Minn. Stat. § 116.943 (Amara's Law)
  • Agency: Minnesota Pollution Control Agency (MPCA)
  • Next deadline: September 15, 2026
  • Portal: prism.pca.state.mn.us
  • Jurisdiction: Minnesota

Source: MPCA PRISM Portal — prism.pca.state.mn.us · Verified April 2026

Full state guide: pfasdisclosure.com/states/minnesota

Disclaimer: This entry provides compliance information for reference only and does not constitute legal advice.

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