US PFAS Reporting Rule Resets to January 31, 2027: What Leather Jacket Importers Must File

US PFAS Reporting Rule Resets to January 31, 2027: What Leather Jacket Importers Must File

Summary

On April 13, 2026, the US Environmental Protection Agency published a final rule that moves the start of the data submission period under the TSCA PFAS Reporting Rule to January 31, 2027, or 60 days after a further EPA action, whichever is earlier. The rule covers companies that manufactured or imported PFAS, including PFAS contained in articles, in any year from 2011 through 2022. That scope reaches leather jacket importers, not only chemical producers.

US PFAS Reporting Rule Resets to January 31, 2027: What Leather Jacket Importers Must File

On April 13, 2026, the US Environmental Protection Agency published a final rule that moves the start of the data submission period under the TSCA PFAS Reporting Rule to January 31, 2027, or 60 days after a further EPA action, whichever is earlier. The rule covers companies that manufactured or imported PFAS, including PFAS contained in articles, in any year from 2011 through 2022.

That scope reaches leather jacket importers, not only chemical producers, because the rule counts PFAS that arrives inside an imported article. EPA has also proposed to drop imported articles from the rule entirely. Until that proposal is final, the deadline and the recordkeeping duty stand.

What the TSCA PFAS Reporting Rule Requires

Congress added TSCA section 8(a)(7) in the National Defense Authorization Act for Fiscal Year 2020, and EPA finalized the reporting rule on October 11, 2023. Section 705.5 applies the rule to all chemical substances and mixtures containing a chemical substance, including articles, that are PFAS.

Section 705.10 sets out who must report: any person that manufactured a PFAS for commercial purposes at any time from January 1, 2011 through the end of the last calendar year before November 13, 2023. The submission is one-time, and information must be reported to the extent it is known to or reasonably ascertainable by the reporter.

Reports go to EPA through the Central Data Exchange, using the PFAS 8(a)(7) reporting tool. Records documenting what was reported must be retained for 5 years beginning on the last day of the submission period.

The New Dates and the Window for Smaller Importers

The April 13, 2026 final rule is the third change to the timetable. EPA moved the start from November 12, 2024 to July 11, 2025 in September 2024, and then to April 13, 2026 in May 2025, in both cases because the electronic reporting application was still being built and tested.

Under section 705.20 of the amended 40 CFR part 705, the standard submission period runs for six months from the date it opens. A reporter that files only as an article importer and also qualifies as a small manufacturer gets 12 months instead.

What EPA Wants to Change About Imported Articles

On November 13, 2025, EPA proposed to exempt PFAS imported as part of an article from the reportable activities, amending sections 705.5, 705.12, 705.18 and 705.30. In the proposal, the agency states that requiring reporting from importers of articles containing PFAS exceeds its authority under TSCA section 8(a)(7).

EPA also made a practical case. Importers of articles are unlikely to know, or to be able to establish, which PFAS content crossed the border between 2011 and 2022, and safety data sheets rarely recorded it. The comment period closed on December 29, 2025, and the docket holds more than 9,000 comments.

EPA has said it expects to finalize the revisions before January 31, 2027 and to remove the fallback date afterwards. Even if imported articles leave the scope, the agency would still receive information about PFAS in articles through manufacturers' processing and use reporting.

Stacked tan and dark brown leather hides on a wooden workbench, ready for leather jacket production.

What Leather Jacket Buyers Should Prepare Now

For a leather jacket programme, the rule turns on two questions: what the tannery and the finishing plant applied to the material, and in which years that material crossed the border. Both belong in the specification file rather than in a folder opened at the last minute.

For each style, keep the finish chemistry and any PFAS declaration from the supplier, the year of import, and the quantities involved. Article importer reporting under section 705.18(a) works from what is known or reasonably ascertainable, with quantities reported in pounds, tons or units of the imported article.

The wider chemical file moves in the same direction. California set a lower PFAS limit for textile articles from 2027, and the EU PFHxA restriction applies to apparel textiles from October 10, 2026. Requesting the same supplier documents once for all three saves work later in the season.

Danke, the export programme of Dalian Danke Fashion Co., Ltd, produces custom leather jackets for B2B buyers and keeps material documents per style, including the finish records a buyer needs for its own file. The range is published at www.dankeleatherjacket.com, and material questions can go to the export team on WhatsApp at +86 13234076432.

Frequently Asked Questions

Does the TSCA PFAS Reporting Rule apply to leather jacket importers?

As written, yes, if the importer brought in an article containing a PFAS in any year from 2011 through 2022. EPA has proposed to exempt PFAS imported in articles, and that proposal is not final.

When does the reporting period start?

January 31, 2027, or 60 days after a further EPA final rule on the substance of the requirements, whichever is earlier. The standard period lasts six months, and 12 months for a small manufacturer reporting only as an article importer.

What records must be kept?

Records that document the information reported must be kept for 5 years beginning on the last day of the submission period.