Original article (May 6): ILMA has submitted a letter to the Trump administration urging the EPA to amend its PFAS reporting rule under TSCA Section 8(a)(7). The Association requested an extension of the reporting deadline and the reinstatement of burden-reduction mechanisms—most notably, the longstanding de minimis exemption that the EPA eliminated in its final PFAS reporting rule.

ILMA argued that the removal of the de minimis exemption departs from established TSCA practice and imposes disproportionate costs on small businesses by requiring nearly impossible, trace-level retrospective data gathering on PFAS dating back to 2011. ILMA’s proposal includes amendments that would provide for small business exemptions and establish low-concentration exclusions for reporting. These changes would promote regulatory flexibility while ensuring the EPA receives meaningful data regarding PFAS activities.

Other chemical industry stakeholders are also seeking regulatory relief. A coalition of chemical companies recently submitted a formal petition to the EPA under TSCA Section 21. Similar to ILMA’s request, the coalition seeks standard exemptions typically found in other TSCA Section 8(a) reporting requirements, such as the low-volume de minimis exemption and exclusions for byproducts, impurities, imported articles, and R&D substances.

Given the EPA’s recent statements that its reporting framework should not overburden small businesses and article importers, ILMA hopes the agency will grant its petition and will delay the compliance period until burden-reduction mechanisms are integrated into the PFAS reporting rule.

“Under the former administration, the EPA really stretched its statutory authority, ignoring burden reduction as a longstanding principle of TSCA reporting,” said ILMA CEO Holly Alfano. “The agency should reverse course, listen to ILMA and other stakeholders, and grant the PFAS reporting petitions.”