Per- and Polyfluoroalkyl Substances (PFAS) are widely used in industrial production and daily life due to their excellent properties such as heat resistance and water repellency. However, their environmental persistence and potential health risks have also made them a focus of global environmental regulation. Recently, the U.S. Environmental Protection Agency (EPA) issued an important proposal, intending to targeted optimize the reporting and regulatory scope of PFAS in accordance with the Toxic Substances Control Act (TSCA). The aim is to inject a more pragmatic governance logic into the PFAS regulatory system by eliminating redundant reporting requirements, clarifying exemption scenarios, and other measures, while reducing the compliance burden on enterprises and ensuring the effective acquisition of key safety information.

The core of this proposal lies in building a "precision regulation" framework. While retaining key reporting obligations, it clarifies six categories of exemption scenarios, delineating clear regulatory boundaries for PFAS production and import activities under different circumstances. Among them, the exemption based on concentration threshold is quite representative - PFAS production and import activities where the concentration in mixtures or products is 0.1% or lower are exempted. This standard not only aligns with the scientific consensus that low-concentration PFAS pose relatively lower risks but also avoids excessive reporting of trace components by enterprises. In addition, exemptions for scenarios such as imported articles, specific by-products, impurities, chemicals for research and development, and non-isolated intermediates address the practical needs of different fields including trade circulation, production auxiliary processes, and scientific research respectively, reflecting the adaptability of regulation to industrial practices.

This regulatory optimization is not proposed out of thin air but is a targeted correction of the flaws in the previous regulatory rules. In October 2023, the EPA during the Biden administration issued the one-time PFAS reporting and recordkeeping rule in accordance with Section 8(a)(7) of TSCA, requiring manufacturers who had produced or imported PFAS in any year between 2011 and 2022 to submit data related to exposure and existing environmental and health impacts to the EPA. Soon after the implementation of this rule, a series of problems emerged: from the cost perspective, the compliance cost for enterprises reached nearly $1 billion, imposing a heavy burden on small businesses and importers; from the efficiency perspective, the rule failed to establish a clear data utilization framework, making it difficult for the massive collected data to be transformed into effective environmental governance measures; from the implementation level, the lack of operable implementation standards, coupled with IT system failures and administrative process delays, led to numerous difficulties in regulatory implementation. Eventually, it fell into a dilemma of "high cost and low efficiency", failing to achieve environmental protection goals and restricting the normal development of the industry.

Compared with the previous rules, the proposed revision highlights two core principles: "balance between cost and benefit" and "regulatory certainty". In terms of cost control, through exempting non-essential reporting scenarios, it is expected to achieve a net reduction in regulatory costs, allowing enterprises, especially small and medium-sized ones, to invest more resources in the core links of PFAS risk prevention and control. In terms of regulatory effectiveness, it does not simply lower standards but ensures that the EPA obtains the most relevant data for regulatory objectives by focusing on high-risk scenarios, thereby improving regulatory precision. At the same time, the technical correction measures in the proposal - clarifying the reporting requirements for certain data fields and adjusting the data submission time limit - directly address the pain points in the implementation of the previous rules, providing clear guidance for enterprise compliance and reducing reporting errors and process delays caused by ambiguous rules.

The regulatory governance of PFAS has always faced the dual challenges of "risk prevention and control" and "industrial development". This proposal by the U.S. EPA provides an important governance idea for global PFAS regulation: effective environmental regulation should not be a one-size-fits-all strict requirement, but a precision policy based on scientific cognition and combined with industrial reality. By clarifying regulatory boundaries and reducing redundant burdens, concentrating regulatory resources on key risk points can not only ensure environmental safety and public health but also leave sufficient space for industrial innovation. Of course, the proposal is still in the proposed stage, and its final implementation effect needs to be observed in the subsequent public comment collection and improvement of implementation details. However, it is certain that this regulatory orientation of "pragmatic feasibility, precision and efficiency" will lay an important foundation for promoting PFAS regulation from "formal compliance" to "substantial effectiveness".