How to Complete the EPA PFAS Reporting Form in 2026

If you manufacture, import, or process PFAS or PFAS-containing articles, you've likely received notice about EPA's one-time reporting requirement under TSCA. The deadline is fast approaching, and the form—EPA Form 8700-23—is detailed and unforgiving. This guide walks you through the process step by step, so you can submit complete and accurate data without last-minute scrambling.

Step 1: Confirm whether you must report

Before you touch the form, verify that your activities trigger the reporting obligation. The rule, codified at 40 CFR 705, applies to anyone who manufactured (including imported) or processed PFAS or PFAS-containing articles in any year since January 1, 2011. That includes importers of articles containing PFAS, not just chemical manufacturers.

Check EPA's list of PFAS for reporting—currently over 1,400 substances—to see if your chemicals are covered. If you're unsure, EPA's reporting tool has a searchable database. If your PFAS is on the list and you had any volume, even for research or pilot scale, you must report.

Step 2: Gather the required data before you start

The form asks for information across several categories, and you'll want everything on hand before opening the online portal. Missing data is the most common reason for incomplete submissions.

Collect the following for each PFAS and each year:

• Production volume (in pounds) for each calendar year from 2011 onward
• Import and export volumes, if applicable
• Industrial processing and use information, including the function and category
• Consumer and commercial use details
• Environmental and health effects data, if you have it
• Number of workers exposed at your site
• Disposal and release data, including any releases to air, water, or land

You'll also need your company's Dun & Bradstreet number and your facility's NAICS code. If you don't have historical production records, now is the time to dig through archives or contact your supply chain.

Step 3: Understand the online submission system

EPA requires electronic submission through its CDX (Central Data Exchange) portal. You'll need to create an account and register your company before you can access the form. This registration process itself can take a few days, so don't leave it to the last minute.

Once registered, you'll use EPA's e-PCG (electronic Premanufacture Notice) system to access the PFAS reporting form. The system allows you to save your progress, so you can work on the form across multiple sessions. However, you must certify and submit before the deadline—there's no partial submission option.

Step 4: Fill out the form section by section

Section 1: Company and facility identification

Enter your legal company name, D&B number, and the facility address where the PFAS activity occurred. If you reported under a different name in the past, include that in the comments field. Be precise—EPA will use this to match your submission to any existing TSCA records.

Section 2: Chemical identification

List each PFAS you're reporting, using the specific chemical name and CAS number from EPA's list. Do not use trade names or generic descriptions—the system expects the exact identifier from the rule. If you have a mixture containing multiple PFAS, you must report each PFAS separately, not the mixture as a whole.

Section 3: Production and import volumes

For each PFAS and each year from 2011 through the most recent complete year, enter the total volume in pounds. You can report by calendar year or fiscal year, but be consistent—EPA will compare across years. If you had zero production in a given year but imported articles containing PFAS, that still counts and must be reported.

Volume thresholds matter here. If your annual volume was under 10,000 pounds for all years, you can submit a reduced reporting form, but you still need to provide the same basic information. If you exceeded 10,000 pounds in any year, you must complete the full form.

Section 4: Use and exposure information

This is where you describe how the PFAS was used. Select the appropriate industrial function category from EPA's list (e.g., surfactant, flame retardant, coating). For each use, indicate the consumer or commercial product category, and estimate the number of workers potentially exposed at your site.

Be as specific as possible. Vague entries like "various uses" will trigger follow-up questions or rejection. If you don't know the downstream uses, state that you have no knowledge and provide the reason, but note that EPA expects you to make a reasonable inquiry of your customers.

Section 5: Environmental and health effects

If you possess any unpublished health or environmental effects data, you must submit it. This includes studies from your own research, from contractors, or from trade associations. If you have no such data, state that clearly—don't leave it blank. EPA uses this section to identify data gaps, so accurate "no data" responses are acceptable.

Section 6: Disposal and releases

Report any known releases of PFAS to air, water, or land, including from waste disposal. This includes releases that occurred during manufacturing, processing, or from article use. If you don't have specific release data, provide your best estimate based on mass balance or industry averages, and note the basis for your estimate.

Step 5: Review, certify, and submit

Before you certify, go through each section and double-check your numbers. Common errors include inconsistent units (pounds vs. kilograms), missing CAS numbers, and incomplete year coverage. The system will flag some errors, but not all—you're responsible for the accuracy.

Certify the form electronically, which constitutes your signature under TSCA. Once submitted, you'll receive a confirmation number. Keep that for your records. You can submit amendments later if you find errors, but avoid that by reviewing carefully now.

Common mistakes and how to avoid them

The biggest mistake is waiting until the week before the deadline. CDX registration, data gathering, and form completion can easily take a month. Start now.

Another frequent error is reporting mixtures as a single PFAS. Remember, each PFAS in a mixture must be reported separately. Also, don't forget imported articles—if you import textiles, electronics, or packaging containing PFAS, you're covered. Finally, don't assume de minimis exemptions apply—the rule has no de minimis threshold for reporting.

Closing takeaway

The EPA PFAS reporting form is complex, but manageable if you approach it methodically. Confirm your obligation, gather your data, and use the online system's save feature to work through it in stages. The deadline is fixed, so plan backward from that date. If you're uncertain about any requirement, EPA's compliance guidance documents and the rule text at 40 CFR 705 provide the details. Submit early, and you'll avoid the stress of a last-minute filing.