David Quigley Quoted in Chemical Watch Article ‘New Mexico to use PRISM platform for PFAS reporting.’

Head of Akin’s environment & natural resources practice David Quigley is quoted by Chemical Watch News & Insight in an article titled, “New Mexico to use PRISM platform for PFAS reporting,” discussing New Mexico’s decision to adopt the Per- and Polyfluoroalkyl Substances (PFAS) Reporting Information System for Manufacturers (PRISM) for PFAS disclosures already used in Minnesota. The article draws on remarks David delivered at the PFAS Global Conference hosted by Chemical Watch, where he discussed the PFAS regulatory environment.

I was honored to present once again at the American Conference Institute’s (ACI) Annual Summit on PFAS Regulation, Compliance and Litigation, this year as part of a great state regulatory panel. Below are some thoughts from the conference:

After the U.S. Environmental Protection Agency (EPA) delayed the submission period for its one-time per- and polyfluoroalkyl substances (PFAS) reporting requirement under the Toxic Substances Control Act, Minnesota just extended its own (previously extended) PFAS products reporting deadline from July 1, 2026, to September 15, 2026. The Minnesota Pollution Control Agency cited challenges in collecting and submitting data under the state’s reporting rule, adopted in December 2025, as necessitating the delay. That rule requires manufacturers of intentionally added PFAS-containing products to submit a description of each product and the concentration and function of PFAS in it. Manufacturers unable to meet the new deadline may request a single, 90-day extension, which would extend reporting to December 2026. The Agency notes that 18 companies submitted reports ahead of the original deadline, data from which (except for protected trade secrets) is now publicly available. Given the fluidity of the rules and the deadlines, we continue to advise submitting closer to the (now later) end of the reporting period.

On April 9, 2026, the Environmental Protection Agency (EPA) announced a long-anticipated delay in the reporting window for the per- and polyfluoroalkyl substances (PFAS) reporting rule under the Toxic Substances Control Act (TSCA). In October 2023, EPA imposed a one-time requirement under TSCA on entities that manufactured (including imported) PFAS or PFAS containing products between 2011 and 2022 to submit to EPA information regarding PFAS exposure and environmental and health effects. After two extensions due to delays in developing the web-based reporting portal, the reporting window under the rule was set to open on April 13, 2026, and close on October 13, 2026. As the opening date approached, EPA proposed a partial rollback of the rule that would both exempt certain categories of PFAS from the reporting requirements and change the reporting period (a prior PFAS Press blog post discusses the proposed rollback) but until today it had not formally cancelled the original start date. With the announcement, EPA resolved the uncertainty, confirming that reporting will not commence on April 13 and instead will begin only 60 days after the revised rule becomes effective (although questions still remain as to whether EPA will shorten the reporting window from the original six months to the proposed three months). EPA plans to issue a final rule on reporting later this year, with updated guidance and reporting tools accompanying the revised requirements.