USEPA Includes PFAS Regulatory Updates in Unified Agenda
On September 4, 2025, the U.S. Environmental Protection Agency (USEPA) provided several PFAS rulemaking updates in the Office of Information and Regulatory Affairs’ Spring 2025 Regulatory Agenda.
Four topics are in the final stage of rulemaking:
- PFAS Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Change of Submission Period – The finalized rule amends the data submission period for TSCA PFAS reporting rule from April 13, 2026 to October 13, 2026, with an alternate end date for small manufacturers reporting exclusively as article importers as of April 13, 2027.
- Toxics Release Inventory (TRI); Clarification to Supplier Notification Provision Due to Automatic Additions of PFAS Under the NDAA – The proposed rule, expected to be finalized in November 2025, clarifies the notification requirement for PFAS automatically added to the TRI under National Defense Authorization Act for Fiscal Year 2020.
- Addition of Certain PFAS to the Toxics Release Inventory (TRI) – The proposed rule, expected to be finalized in February 2026, would add PFAS and PFAS categories to the TRI list of toxic chemicals.
- Listing of Specific PFAS as Hazardous Constituents – The proposed rule, expected to be finalized in April 2026, would add nine PFAS, their salts, and their structural isomers, to its list of hazardous constituents under the Resource Conservation and Recovery Act (RCRA).
Five topics are in the proposed stage of rulemaking:
- Clean Water Act Effluent Limitations Guidelines and Standards for PFAS Manufacturers Under the Organic Chemicals, Plastics and Synthetic Fibers Point Source Category – A proposed rule would address PFAS discharges from certain facilities manufacturing PFAS.
- PFAS Requirements in NPDES Permit Applications – A proposed rulewould include PFAS in the list of pollutants considered during NPDES permit applications by sewage treatment facilities.
- Extending the Compliance Deadline for the PFAS National Primary Drinking Water Regulation Rulemaking – A proposed rule would extend the compliance deadline for PFOA and PFOS.
- Withdrawal of Regulatory Determinations and Removal of Related Provisions for Four PFAS Substances (perfluorohexane sulfonic acid [PFHxS], perfluorononanoic acid [PFNA], hexafluoropropylene oxide dimer acid [HFPO-DA], and the mixture of these three PFAS plus perfluorobutane sulfonic acid [PFBS]) – A proposed rule would remove the regulatory requirements for four PFAS.
- Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping under the Toxic Substances Control Act (TSCA); Revision to Regulation – A proposed rule would incorporate certain exemptions and modifications to the current TSCA reporting rule.
USEPA Files Motion for Patrial Vacatur in the PFAS Drinking Water Regulation Litigation
On September 11, 2025, USEPA filed a Respondents’ Motion for Partial Vacatur (USCA Case #24-1188; Document #2134523) requesting the court vacate final maximum contaminant levels (MCLs) for PFNA, PFHxS, and HFPO-DA, along with the Hazard Index MCL for a mixture of PFNA, PFHxS, HFPO-DA, and PFBS. The motion states, “after further reviewing the statute pursuant to a publicly announced reconsideration process, [US]EPA agrees with petitioners that parts of the rulemaking process were unlawful, and parts of the Rule are thus invalid.” USEPA does not seek vacatur of MCLs for PFOS and PFOA in this motion. USEPA plans to propose a rule this fall to withdraw regulatory determinations for these four PFAS.
USEPA Issues Guidance for PFAS-Impacted Site Assessment
In July 2025, USEPA published a guidance document aimed at providing environmental professionals with a technical resource for conducting PFAS-impacted site assessments. The document covers the following three topics:
- Estimating Site-Specific Groundwater Vulnerability from PFAS-Impacted Soils – The guidance recommends using a PFAS-modified synthetic precipitation leaching procedure to estimate a site-specific dissociation constant (KD) to predict soil screening levels (SSLs) rather than relying on predetermined KD (or normalized partition coefficient [KOC]) values for SSLs, which may underrepresent PFAS behavior due to PFAS sorption to minerals and partitioning at the air-water interface.
- Groundwater Sampling for PFAS – Guidelines for sampling PFAS in groundwater are detailed, such as sample turbidity, sampling equipment, and supplies, recommending a review of past groundwater sampling data to estimate purge volumes prior to sampling.
- PFAS Surface Chemistry and Surfactant Basics – An overview of PFAS chemistry is provided, including tension, contact angles, surfactant properties, and emulsion and foam properties.
New Jersey Publishes Report on Statewide PFAS Soil Investigation
In September 2025, the New Jersey Department of Environmental Protection (NJDEP) published a report and factsheet summarizing the results from a state-wide soil sampling program conducted to characterize the concentration and distribution of PFAS in shallow soils throughout the state. From August to December 2023, a total of 157 surface soil samples were taken from locations with no known sources of PFAS. A total of 40 individual PFAS were analyzed in the study, of which 23 PFAS were detected in at least one sample. Total PFAS concentrations in the samples ranged from non-detect to 34.1 µg/kg. Samples did not exceed the current NJDEP interim soil remediation standards for the ingestion-dermal exposure pathway for PFOS, PFOA, PFNA, and HFPO-DA.
New South Wales Publishes Recommendations for PFAS
In August 2025, the NSW Health Expert Panel released a report on health-related recommendations for PFAS. The Panel reviewed global research on PFAS and concluded that, while PFAS are linked to specific adverse health effects and cancers, “the health effects of PFAS appear to be small”. The panel advised that individual PFAS blood tests offer little clinical benefit and recommended focusing on preventive healthcare, transparent communication, and ongoing monitoring of new scientific findings.
On September 11, 2025, the New South Wales (NSW) Parliament’s Select Committee published a report on PFAS in waterways and drinking water supplies throughout NSW. The report summarized information received from an inquiry that was launched after PFAS were detected in Sydney’s water and regional rivers. The report also makes recommendations including statewide, risk-based PFAS testing with results made public, support for voluntary blood testing in affected towns, stricter reporting by water utilities, and a plan to phase out all non-essential PFAS by 2030.
New Jersey Reaches $2 Billion Settlement with DuPont in PFAS Cleanup Litigation
On August 4, 2025, the State of New Jersey announced it had reached a settlement valued at over two billion dollars with DuPont, Chemours, and Corteva. The settlement addressed PFAS at four industrial sites in New Jersey: Chambers Works, Pompton Lakes, Parlin, and Repauno. The settlement includes a $1.2 billion remediation funding reserve for full site cleanup, an $875 million payment over 25 years to a state fund for restoring natural resources and aiding affected communities, and a $475 million reserve to protect taxpayers if the companies default. The settlement will be published to the New Jersey Register in early September and go to the district court for approval, following a 60-day public comment period.
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