Lynn L. Bergeson, “Reporting PFAS: reporting burden is the least of businesses’ worries,” Financier Worldwide, December 2023.

Ask just about anyone doing business in the US making or importing products that contain chemicals what they think about the US Environmental Protection Agency’s (EPA’s) new per- and polyfluoroalkyl substance (PFAS) reporting rule, and you will get a decidedly grumpy response. Granted, no businessperson welcomes any new chemical reporting obligation, but by any standard, the EPA’s 11 October 2023 final PFAS reporting rule is problematic and is inviting uniquely scathing criticism.