The U.S. Environmental Protection Agency issued a final ruling on Sept. 28 that requires all manufacturers of per- and polyfluoroalkyl substances (PFAS) to submit safety data about any PFAS-containing product made since 2011.
The EPA added 41 more materials to the final ruling for a total of 1,462 PFAS that will be subject to the regulation.
Organizations that have manufactured or imported PFAS since 2011 have 18 months following the effective date of the rule to report PFAS data to the EPA.
Small manufacturers, as defined by the EPA, and whose reporting requirements pertain only to PFAS imports have 24 months from the effective date to submit their PFAS reports.
Meeting that standard could prove difficult for some companies.
Many organizations lack the functional structure in place to gather and assess supplier data they need to meet the regulation by the deadline, says Cally Edgren, senior director of sustainability at Assent, a supply chain sustainability solutions company. Manufacturers that don’t comply face a number of risks, including early supply chain obsolescence, production and sales slowdowns and loss of customers due to non-compliance coupled with an inability to provide them with data.
But companies that proactively pursue compliance could benefit from the ruling, she says.
“Being proactive, beyond basic compliance with the new EPA ruling, will benefit companies and their customers, stakeholders and investors,” Edgren says. “Companies that engage their supply chains to meet the enhanced data collection required through this final ruling will also gain the opportunity to proactively gather information for other PFAS regulations as well. This will help mitigate risks of fines, legal action, potential loss of market access, and supply chain disruptions resulting from product obsolescence.”
The EPA ruling also could spur innovation for substitutes to existing PFAS chemicals currently used in products and parts, she says.
