USEPA Proposes Changes to PFAS TSCA Reporting Requirements
On November 10, 2025, the U.S. Environmental Protection Agency (USEPA) released a pre-publication version of proposed amendments to its PFAS reporting rule under Section 8(a)(7) of the Toxic Substances Control Act (TSCA). The amendments would reduce reporting obligations for PFAS manufactured or imported from 2011 through 2022. Under the revised framework, reporting would not be required when PFAS are present in articles or mixtures at concentrations less than 0.1% by weight, occur as impurities or non-isolated intermediates, are used in research and development, or are byproducts not used commercially. If finalized, the submission period would begin 60 days after the final rule’s effective date and shorten the submission window from six to three months. Public comments on the proposal can be submitted online by December 29, 2025.
Request for Stay Granted in PFAS CERCLA Superfund Litigation
On October 31, 2025, the U.S. District Court for the District of South Carolina granted a motion to stay 22 pending Superfund cases within the multidistrict litigation concerning PFAS contamination from aqueous film-forming foam (AFFF). The stay was issued due to the lapse in appropriations that began on October 1, 2025, which barred the Department of Justice from engaging in litigation activities during the federal shutdown. The affected cases primarily involve local governments seeking cost recovery and contribution under CERCLA for PFAS remediation costs. The order pauses all proceedings “until Congress has appropriated funds for the Department of Justice, and all pending deadlines in the stayed cases are extended for the same number of days as the lapse in funding.”
USEPA Approves Fluorinated Pesticide Active Ingredients
On November 5 and November 20, 2025, USEPA approved the use of two new fluorinated pesticide active ingredients, cyclobutrifluram and isocycloseram, respectively.
- Cyclobutrifluram targets nematodes and fungi and is approved for use on grass turf, ornamentals, romaine lettuce, and cotton and soybean seeds.
- Isocycloseram is a broad-spectrum contact insecticide and is approved for use on agricultural crops, turf and ornamentals, as well as indoor and outdoor uses for commercial, industrial and domestic sites.
Active ingredients in pesticides are subject to USEPA review, including review of mammalian and ecological toxicity and environmental fate. Cyclobutrifluram and isocycloseram contain a single fully fluorinated carbon moiety (CF3), which can degrade to trifluoroacetic acid (TFA) under environmental conditions. TFA is a highly mobile and persistent short-chain PFAS that has recently attracted increasing interest from researchers and regulatory agencies.
California Updates PFAS Response and Notification Levels for Drinking Water
On October 29, 2025, the California Division of Drinking Water issued new and revised notification levels and response levels for four PFAS. Revised values were issued for PFOA, PFOS, and perfluorohexanesulfonic acid (PFHxS), and new values were issued for perfluorohexanoic acid (PFHxA). Former and current notification and response levels are summarized in the table below:
NL: notification level; RL: response level
ng/L = nanogram per liter
Notification levels are non-regulatory health-based advisory values that represent the concentration of a substance in drinking water that, if exceeded, would not be expected to pose significant health risks but would require notice to the State and customers. Response levels indicate the concentration of a substance in drinking water that, if exceeded, would merit action beyond notification, such as taking the source out of service.
Updated PFAS Restrictions Proposed Under EU REACH
In October 2025, authorities from five European Union (EU) countries, including Sweden, Germany, Norway, Denmark, and the Netherlands, published a report summarizing key updates made to a more extensive Background Document on proposed PFAS restrictions under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation. REACH governs the production, import, and use of chemical substances within the EU. The summary report and Background Document assess environmental and human health risks associated with PFAS across various sectors, building on the original 2023 REACH Regulation Annex XV report.
A detailed impact assessment was conducted, comparing the costs of various restrictions to the expected reduction in PFAS emissions. Restrictions evaluated included a full ban, time-limited exemptions, and continued use under strict conditions. Based on the assessment and new evidence about viable alternatives in specific sectors, changes were made to the proposed restrictions and derogations. The European Chemicals Agency (ECHA) is now conducting an evaluation of the updated proposal, and thereafter, the EU Commission will decide on the PFAS Restrictions.
Geosyntec PFAS Webinar Series
Geosyntec hosted a PFAS webinar series showcasing a thorough synthesis of the state of knowledge on the management of PFAS-impacted sites. Subject matter experts from Geosyntec and the broader stakeholder community discussed key PFAS technical, regulatory, and legal issues.
To view webinar recordings of this six-part PFAS series as well as other archived PFAS webinars, visit Geosyntec PFAS Webinar Series.
Questions?
If you have any questions or would like to discuss how PFAS may impact your business, please email pfas@geosyntec.com to be connected with one of our PFAS technical experts.
