The EPA's 2026 TSCA Section 8(a)(7) reporting window is officially open. We provide the technical due diligence and legal safeguards to ensure your market access remains uninterrupted.
The Regulatory Landscape
Most manufacturers don't realize the full scope of what "known or reasonably ascertainable" actually demands โ until it's too late.
The EPA requires you to report PFAS use and manufacture from January 1, 2011 through December 31, 2022. That means tracking down records from suppliers, subsidiaries, and product lines that may no longer exist โ across a full decade of operations.
The EPA's standard is not limited to what you know โ it extends to what you should have known. Failure to conduct adequate supply chain due diligence is itself a violation, even if you never used PFAS directly.
Finished goods ("articles") containing PFAS are subject to reporting if they were imported or manufactured for commercial purposes. Many importers are unaware their products qualify โ creating silent, compounding liability.
Minnesota's PFAS reporting requirements take effect in 2026 with stricter thresholds than federal law. Companies selling into Minnesota must comply with both frameworks simultaneously โ with different definitions, timelines, and submission portals.
The EPA's Central Data Exchange (CDX) portal requires specific technical formatting, CBI (Confidential Business Information) designations, and multi-step authentication. A single submission error can trigger a formal Notice of Violation.
Our regulatory team has processed hundreds of TSCA submissions. We know exactly where companies make costly mistakes โ and we eliminate those risks before they become penalties.
Talk to an Expert TodayWhat We Do
Every engagement is outcome-driven. We take ownership of your compliance process from data gathering to final CDX submission.
We eliminate your submission liability by managing the entire reporting lifecycle โ from historical data excavation to final CDX portal submission with CBI protections intact.
We map your entire upstream supply chain to identify PFAS in articles, imported mixtures, and component-level materials โ before the EPA does it for you.
We determine whether you qualify for the 0.1% de minimis threshold, R&D exemptions, or article exemptions โ and build the documented legal defense to support your position.
We manage dual-track compliance for companies operating in Minnesota, ensuring your state-level submissions align with โ but don't conflict with โ federal TSCA obligations.
PFAS regulations are evolving rapidly. We keep you ahead of EPA guidance updates, state-level expansions, and emerging TSCA actions โ so you're never caught reacting.
Schedule a 30-minute complimentary scoping call. We'll assess your exposure profile and tell you exactly what's required โ at no cost.
Book Free Scoping CallNo sales pressure. Straight answers.
How It Works
A structured, repeatable methodology refined across hundreds of TSCA engagements.
We conduct a rapid 48-hour intake to map your product lines, supply chain depth, and historical PFAS exposure. You receive a written risk profile before any engagement begins.
Our team deploys structured supplier questionnaires, reviews import records, and cross-references SDS documentation to build your complete 12-year PFAS data inventory.
We build your CDX-formatted submission, apply appropriate CBI designations, and conduct a multi-layer QA review to eliminate errors before submission.
We submit on your behalf and maintain a complete audit-ready documentation package. If EPA follow-up occurs, we represent your position with documented evidence.
Client Results
A regional electronics manufacturer came to us 90 days before the reporting window opened. Their internal team had attempted to self-assess using the EPA's published guidance โ and concluded they had "no reportable PFAS." Our forensic audit told a different story.
"ClearPath found PFAS exposure in our supply chain that three internal reviews missed. Their CDX submission was flawless. We had zero follow-up from EPA."โ VP of Operations, Tier-2 Aerospace Supplier
"The exemption analysis alone saved us from over-reporting 60% of our product line. That's a material reduction in future compliance burden."โ General Counsel, Industrial Textiles Manufacturer
"We had 90 days and a supply chain spanning 14 countries. ClearPath delivered a complete, defensible submission in 8 weeks. Exceptional team."โ Chief Compliance Officer, Automotive Components Importer
Free Resource
Updated for February 2026 EPA Guidance โ the most current compliance framework available.
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Get Started
Every week of delay narrows your window for thorough data collection. The companies that engage now will submit with confidence. The ones that wait will scramble.
Every inquiry receives a substantive response from a senior consultant within 48 business hours.
Engagements structured through our legal team can qualify for privilege protection on all communications.
No hourly billing surprises. We scope your project upfront and deliver at a fixed price.
30 minutes. No obligation. Clear answers.