with Our Product Environmental Compliance SaaS Application

Yes, we help with supplier data collection to get PFAS declaration and store in iLenSys compliance manager tool as evidence post validation. For non-responding suppliers or where we don't get PFAS compliance we use another approach to study and screen parts for PFAS and document in compliance tool.

CDX portal will be open for reporting from Nov 2024.

Yes, you are correct.

US PFAS Reportable substances - Which PFAS substances covered in US TSCA PFAS reporting scope are below defined structure of PFAS substances only.

1. R-(CF2)-CF(R’)R’’, where both the CF2 and CF moieties are saturated carbons; 
2. R-CF2OCF2-R’, where R and R’ can either be F, O, or saturated carbons; and  
3. CF3C(CF3)R’R’’, where R’ and R’’ can either be F or saturated carbons. 

There is a discrete list of identified 1462 PFAS chemicals under reporting obligation 
Higher molecular weight fluoropolymers covered in reporting EU PFAS Proposal which is still under draft/progress is proposed to ban use of PFAS with few derogations.
 
EU PFAS Substances - EU PFAS proposal covers ~10000 PFAS substances for restriction with below structure. 
1. Any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom (without any H/Cl/Br/I attached to it).
2. A substance that only contains the following structural elements is excluded from the scope of the proposed restriction: CF3-X or X-CF2-X’ 

“Article” is defined at 40 CFR 704.3 (referenced by 40 CFR 711.3) as – “Article" means a manufactured item.

- Which is formed to a specific shape or design during manufacture,
- Which has end use function(s) dependent in whole or in part upon its shape or design during end use.
- Has either no change of chemical composition during its end use or only those changes of composition.
- Which have no commercial purpose separate from that of the article; Except that fluids and particles are not considered articles regardless of shape or design. 

Needs to ensure that its importer has completed the reporting obligation (if they are in scope). There is a provision of joint submission which can be explored by suppliers if required.

The supplier needs to ensure if its importer has completed the reporting obligation (if they are in scope). There is a provision of joint submission which can be explored by suppliers if required.

If product have any component with PFAS which is imported in US then importer has reporting obligation.

CDX reporting tool is under testing and EPA is expected to announce readiness of tool for testing in next few months.

Currently EPA is working on developing and testing CDX PFAS reporting portal which is expected to be ready in the next few weeks. We can share excel template with attributes expected to be reported.