Culleen Talks Potential PFAS Reporting Delay With Chemical Watch

Environmental partner Lawrence Culleen was recently quoted in the Chemical Watch article, “TSCA PFAS reporting rule platform may not be ready on time, says EPA chemicals office head,” which discusses the Environmental Protection Agency’s (EPA) rule that requires companies to report information on chemical formulations and manufactured goods produced between January 2011 through the end of 2022 that contained any amount of per- and polyfluoroalkyl substances (PFAS). The submission period is scheduled to run from November 2024 until May 2025.

The head of the EPA’s chemicals office recently stated that the electronic reporting portal (known as CDX) may not be up and running by the beginning of the submission period. Culleen told Chemical Watch that if CDX is not ready in November, reporting “should be delayed until such time as the system is not only available, but also has been extensively beta tested to ensure it is fully functional.” He added that the underlying statute requiring EPA to implement the TSCA PFAS reporting rule does not prevent EPA from postponing the submission date.

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