New Year’s PFAS Updates for 2023

The US Environmental Protection Agency (EPA) has started out 2023 with a round of updates related to proposed per- and polyfluoroalkyl substances (PFAS).

On January 9, 2023, the EPA announced that it would be pushing the release date for its proposed PFAS drinking water standard to March 2023. The EPA’s proposed rule was originally set to be finalized in late 2022, but there have been many detractors that feel the proposed limits for PFAS and PFOA are too low and would place an unreasonable burden on public water supply operators around the country. Whether that or something else has resulted in the delay is purely speculation.

The week prior, on January 4, 2023, the EPA issued a test order for the PFAS trifluoro(trifluoromethyl)oxirane (HFPO), a perfluoroalkyl substance used in making plastics. It will require companies who use this compound in manufacturing processes to conduct and submit testing results to help the agency understand the potential environmental and human health effects of HFPO and compounds similar in chemical structure. Companies that received the test order include the Chemours Company, DuPont, and 3M.

According to the EPA, HFPO (Chemical Abstracts Service Registry Number [CAS RN] 428-59-1) is used in making plastics and in organic chemical manufacturing. More than 1,000,000 pounds of HFPO are manufactured each year, according to TSCA Chemical Data Reporting rule reports. Testing data provided by the order recipients will be made available to the public in docket EPA-HQ-OPPT-2021-0910 on To learn more, see the EPA’s PFAS National Testing Strategy.

The day prior, on January 3, 2023, the EPA announced the addition of certain PFAS to the Toxics Release Inventory (TRI) by the National Defense Authorization Act (NDAA). For the 2022 reporting year, 180 PFAS are reportable. The 2023 reporting year will include an additional nine PFAS. For both years, reporting forms are due July 1, 2023, and July 1, 2024, respectively. The NDAA, signed into law on December 20, 2019, established a framework that identifies certain regulatory activities that automatically add PFAS or classes of PFAS to the TRI list of reportable chemicals. Specifically, PFAS or classes of PFAS are added to the TRI list of reportable chemicals beginning January 1 of the calendar year. Compounds can also be added after other types of designations, such as a significant new use rule (SNUR) determination. The NDAA also establishes reporting thresholds for TRI manufacturing, processing, and otherwise use reporting thresholds of 100 pounds for each of the listed PFAS.

Newly Reportable for the Current Reporting Year and Next Reporting Year

CAS RN TRI Chemical Name Effective Reporting Year
375-73-5 Perfluorobutane sulfonic acid 2022
29420-49-3 Potassium perfluorobutane sulfonate 2022
45187-15-3 Perfluorobutanesulfonate 2022
203743-03-7 2-Propenoic acid, 2-methyl-, hexadecyl ester, polymers with 2-hydroxyethyl methacrylate, γ-ω-perfluoro-C10-16-alkyl acrylate and stearyl methacrylate 2022
375-22-4 Perfluorobutanoic acid 2023
2218-54-4 Sodium perfluorobutanoate 2023
2966-54-3 Potassium heptafluorobutanoate 2023
10495-86-0 Ammonium perfluorobutanoate 2023
45048-62-2 Perfluorobutanoate 2023
2728655-42-1 Alcohols, C8-16, γ-ω-perfluoro, reaction products with 1,6-diisocyanatohexane, glycidol and stearyl alc. 2023
2738952-61-7 Acetamide, N-[3-(dimethylamino)propyl]-, 2-[(γ-ω-perfluoro-C4-20-alkyl)thio] derivs. 2023
2742694-36-4 Acetamide, N-(2-aminoethyl)-, 2-[(γ-ω-perfluoro-C4-20-alkyl)thio] derivs., polymers with N1,N1-dimethyl-1,3-propanediamine, epichlorohydrin and ethylenediamine, oxidized 2023
2744262-09-5 Acetic acid, 2-[(γ-ω-perfluoro-C4-20-alkyl)thio] derivs., 2-hydroxypropyl esters 2023

Stay tuned for more updates as the EPA seems to be off to a busy start this year! For more information on PFAS or related services that Apex Companies offers, see Remediation, Our Projects, or download our PFAS Solutions brochure. Alternately, you can always reach out to us at or submit a Capabilities Inquiry to have a project manager connect with you to discuss your specific needs.

Apex Associated Press (Apex AP) represents contributions from various authors within the Apex professional community.


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