Due Dates and Important Points for the 2026 Reporting Period.

​Manufacturers of children’s products containing High Priority Chemicals for Children Health (HPCCCH) at de minimis, which are sold or offered for sale in Oregon in 2024 and 2025 (the 2026 Reporting Period), must make those reports on or before January 31, 2026.^​ See Oregon Revised Statute (ORS)​ 431A.253 for definition of "de minimis" for the TFK Act and its rules.

Reports are to be made to the High Priority Chemicals Data System (HPCDS). See HPCDS Reporting Guide for reporting instructions. For the Create Report step for reporting in the HPCDS, the 2026 Reporting Period choice­ will become available on December 15, 2025. [In the dropdown, that choice looks like 2026 (due 1/31/2026).]  Do not report products sold or offered for sale in 2024 in either this December or January 2025. The 2026 Reporting Period choice will not be available until December 2025.

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In addition to the points in red above, manufacturers will not likely have all the data necessary to report correctly before December 15th.  To understand why and which data is required, we recommend you review FAQs 8,16 and 17 in​ the Reporting for the Toxic Free Kids Act group of Frequently Asked Questions (FAQs). 

​If you are to make the third report of a HPCCCH in a subset of children's products affected by Oregon Administrative Rule (OAR) 333-016-3010(1), we recommend you start preparing for the HPCCCH Removal/Substitution Requirement or requests for Waiver and Exemptions from Removal/Substitution now. 

Manufacturer may request an Exemption from Notice Requirement supported by a Manufacturing Control Program (MCP) for product in a GS1 product category where the HPCCCH in a product category/HPCCCH combination is a contaminant and found at concentrations above de minimis. This type of exemption is not available for intentionally added HPCCCH. See ORS​ 431A.253 for definitions of "contaminant" and "intentionally added."

For products affected by OAR 333-016-3010(1), an Exemption from Notice Requirement/(MCP)​request may ​only be made on or before the date on which biennial notices/reports are due for those products' first, second, ​or third biennial notice/reporting period. ​ 

For other children's products containing a HPCCCH as a contaminant, ​but not affected by OAR 333-016-3010(1), OHA will accept such requests for any biennial notice period. Exemption Requests/MCPs must be received by the Authority on or before the date ​that biennial notices/reports are due (January 31st) following the two-year biennial notice period for which the Request is being made.​ 

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As stated in FAQs #31, and #37 and #41, ​OHA will accept request for both types of exemptions; waivers; substitutions of HPCCCH(s); or notices that HPCCCH(s) have been removed from children's products, on or before January 31, 2026.

The Fee Payment & Application Upload Portal is used to upload documentation for both types of exemptions; waivers; and substitutions of HPCCCH(s). In addition, the $1500 application fee is paid and the documentation for a request uploaded at this secure website. The Portal will open to receive documentation and payments in December 2025.

IMPORTANT: When paying by credit card, the address entered must be the same as the billing address known to the credit card company. If it is not, the payment will be rejected and your submission will not be accepted by OHA.

Still have questions? Email ​toxicfreekids.program@odhsoha.oregon.gov

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