Do you use fluorocarbon (FKM, Viton®), fluorosilicone (FVMQ), FFKM (perfluoroelastomer, Kalrez, Simriz, etc.), or AFLAS? Then there are EPA reporting rules that could apply to your business. All these elastomers are classified as PFAS, a category of widely used chemicals that have been the focus of regulations.
Are you physically creating (i.e., manufacturing) PFAS-containing elastomers? If you’re not, then your reporting requirements are limited to when you import these materials into the United States. “Importing” means that your company is listed on the U.S. Customs paperwork and physically bringing PFAS-containing products into the country.
Are you using a third-party company (such as a distributor) to import PFAS-containing materials instead? Then your company is not required to comply with EPA reporting rules. If you’re wondering what these reporting requirements are like, please see our article called PFAS Reporting and Your Business. We always recommend that companies check with their legal counsel on regulatory items. We’ve also compiled a list of PFAS Resources.
What’s the bottom line? Manufacturers of PFAS-containing elastomers face the most detailed reporting requirements. Direct importers are also bound by reporting requirements, but they’re less detailed. Finally, companies that do not directly import PFAS-containing elastomers are not required to complete EPA reporting.
EPA PFAS Filing Deadline Extended
Are you ready for some good news? The EPA has extended the start and end of the reporting period. This is due to budget constraints and scarce IT resources. The new start of the reporting period is July 2025. For most reporters, the deadline to submit is now January 22, 2026.
The Rubber Group will continue to update our customers about new developments, including additional attempts to classify fluorine-based rubbers as banned substances under REACH and U.S. state and federal regulations. We are also continuing to work closely with our industry trade group, the Association for Rubber Product Manufacturers (ARPM).
Contact The Rubber Group for more information.