Document zNRVJXjqwvJXdDLG7GRK6da3

March 14, 2025 Dr. Lynn Dekleva Office of Pollution Prevention and Toxics Environmental Protection Agency 1200 Pennsylvania Ave. NW Washington, DC 20460-0001 RE: Extension of Reporting Submission Period; Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Change to Submission Period; EPA-HQ-OPPT-2020-0549 Dear Dr. Dekleva: The undersigned organizations urge you to extend the submission date for the Toxic Substances Control Act 8(a)7 Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) by at least an additional six months -- after the beta testing of the application has completed, the application has been made public, and clear agency guidance is published. EPA has previously determined that the resources and technical capability to effectively execute the requirements of the rule were not practically in place, and accordingly, extended the submission period start date from November 12, 2024 to July 11, 2025. 89 Fed. Reg. 72,336 (Sept. 5, 2025). These facts persist and should compel the agency to act immediately to grant additional compliance time while the agency addresses unresolved implementation challenges. This extension will also allow EPA to thoroughly consider initiating a new rulemaking that executes needed changes to this TSCA reporting rule before regulated entities make significant expenditures building compliance plans. In a letter earlier this year to Administrator Zeldinl, we recommended that EPA modify the rule to reduce the burden on businesses by recognizing that the rule's broad and somewhat unprecedented data collection approach is unnecessary to meet TSCA's statutory requirements. EPA should provide a phased, two-tiered system that acknowledges the value of collecting data from major sources, reconsiders the need for information from small business and other insignificant data, and offers initial exemptions consistent with other TSCA reporting requirements. These important changes will reduce the potential cost burden, especially on small businesses. 1 https://www.uschannber.connienvironnnent/business-coalition-on-pfas-principles-policy-recommendations 1 Sierra Club FOIA Request: 2025-EPA-04193 ED_018475D_00003074-00001 SC_FOIA_0001009 We welcome the opportunity to present these concepts in person and look forward to working with you and your team as this issue proceeds. Sincerely, Alliance for Automotive Innovation Alliance for Chemical Distribution American Apparel & Footwear Association American Chemistry Council American Coatings Association American Fuel & Petrochemical Manufacturers American Petroleum Institute Associated General Contractors of America Fluid Sealing Association Fuel Cell & Hydrogen Energy Association National Asphalt Pavement Association National Association of Manufacturers National Council of Textile Organizations National Mining Association The Chlorine Institute The Fertilizer Institute TRSA -- The Linen, Uniform and Facility Services Association U.S. Chamber of Commerce 2 Sierra Club FOIA Request: 2025-EPA-04193 ED_018475D_00003074-00002 SC_FOIA_0001010