PFAS In 2025: The Wild West Got Even Wilder 

Back in January 2025, few in the PFAS world felt confident making bold predictions about what the year would bring. Looking back now, 2025 was less about brand-new regulatory actions and more about figuring out how to comply with—and in some cases, keep up with—revisions or reversals of rules set in motion over the last several years. To use one of my favorite analogies, you might say the “Wild West” of the PFAS regulatory landscape got even wilder. 

In the sections that follow, we highlight the key PFAS actions taken in 2025 by EPA, other federal agencies, and Congress, and how those actions collectively are reshaping the PFAS world. Reviewing these developments together can help utilities, industry, and community leaders build a solid foundation for decision-making, informing sampling plans, investment priorities, and policy choices as they craft effective PFAS response strategies for 2026 and beyond. 

U.S. EPA ACTIONS 

In a shortened working year shaped by the new administration’s regulatory freeze pending review and a lengthy fiscal shutdown, EPA focused efforts in 2025 on recalibrating the PFAS framework built under the prior administration rather than launching an entirely new regulatory pathway. Many of the PFAS obligations that defined 2025 arose from rules issued in late 2023–2024. After review, some went ahead as planned, while others were slated for adjustment. 

National Primary Drinking Water Regulations (NPDWR) Proposal to Rescind/Retain – In May 2025, EPA announced its intent to retain the MCLs of 4 ppt for PFOA and 4 ppt for PFOS, while eliminating the individual limits for PFHxS, PFNA, and HFPO-DA (GenX) as well as the Hazard Index. These proposed changes were originally expected to be published in late 2025 with finalization in 2026. The government shutdown this fall no doubt delayed the effort, so it’s likely we’ll see the final proposal in Q1. Until then, it’s important to remember that the NPDWR enacted in 2024 remains in effect.  

EPA Makes Public Access to UCMR 5 Data Easier – EPA launched the UCMR 5 Data Finder in in November 2025 to make UCMR 5 occurrence data more accessible and transparent by giving the public, utilities, and regulators an interactive way to search, filter, summarize, and download PFAS and lithium monitoring results from public water systems.  

CERCLA Hazardous Substances and Passive Receiver Debates – After review, EPA chose to keep in place the CERCLA Hazardous Substance designations for PFOA and PFOS that were finalized in 2024, despite litigation and speculation that the designations might be withdrawn. In September 2025, EPA formally told the D.C. Circuit that it will defend those designations and, in parallel, pursue new rulemaking to establish a framework for how any additional PFAS might be designated as CERCLA Hazardous Substances in the future.​  

In November 2025, the Senate committee held a second hearing on PFAS and CERCLA, in which witnesses and senators again devoted substantial attention to how CERCLA liability should treat passive receivers and whether Congress should create special protections for these entities. In February 2025, H.R. 1267, a bill that was designed to protect passive receivers of PFAS was introduced in the House. With EPA Administrator Zeldin pushing the responsibility for passive-receiver protections back to Congress, we’ll be watching for action on this bill or additional proposed legislation in 2026. 

Toxic Substance Control Act (TSCA) Reporting Rules – On November 10, 2025, EPA issued a proposed rule that would significantly amend the TSCA Section 8(a)(7) PFAS Reporting Rule finalized in October 2023. The proposal introduces a de minimis concentration exemption, exempts PFAS in imported articles, and carves out certain byproducts, impurities, R&D substances, and non-isolated intermediates from reporting, while still requiring manufacturers to report retroactively back to January 1, 2011, once the shortened three-month reporting window opens in 2026. 

Effluent Limits and Wastewater Strategy – In an April 2025 release, EPA committed to developing PFAS Effluent Limitation Guidelines (ELGs) for PFAS manufacturers and metal finishers, while evaluating additional ELGs to help combat PFAS contamination. While there are some loose ends for the agency to tie up, e.g., clearer PFAS destruction and disposal guidance for wastewater, proposing specific ELGs, especially for chemical manufacturers, seems like a pretty easy lift. I wouldn’t be surprised to see an initial proposal announced sometime in 2026. 

Annual PFAS Destruction and Disposal Guidance – In the same April press release, EPA also committed to updating its PFAS Destruction and Disposal Guidance more frequently—shifting from every three years to annual updates as it continues to assess the effectiveness of available treatment technologies. Pace® supports numerous PFAS treatability studies, so this is welcome news, and we’re hoping EPA will incorporate newer, novel technologies into future guidance. 

Biosolids Risk Assessment – Early in 2025, EPA released a draft sewage sludge risk assessment for PFOA and PFOS that modeled the typical exposure for a hypothetical “farm family” and found a potential risk at PFOA/PFOS levels above roughly 1 part per billion (ppb) in biosolids. While not yet a binding federal standard, states rapidly treated the 1 ppb level as a de facto ceiling for land-application permits, driving aggressive new testing and management requirements for biosolids programs. We anticipate seeing more action on PFAS in biosolids/wastewater sludge in 2026. 

Ongoing PFAS Testing and TRI Additions – EPA continued to implement the National PFAS Testing Strategy and automatic TRI additions required by prior National Defense Authorization Acts (NDAAs). Facilities that had previously relied on de minimis TRI exemptions found themselves pulled into PFAS reporting when those exemptions were eliminated by an October 2023 rule that went into effect with the 2024 data collection cycle. 

Commitment to Test Method Development – In the April press release, EPA committed to ramping up the development of test methods to improve the detection of PFAS. While nothing has been formally announced, we’ve talked about some of the test method development we’re aware of. See our FAQs on our PFAS.com test method page. That said, test method development is a long and arduous process, so we’re not expecting any significant developments on this front for at least the next year. 

PFAS in Pesticides – EPA’s handling of PFAS in pesticides became especially controversial when, on November 18, 2025, the agency approved the use of two compounds, each containing one fully fluorinated carbon atom, in pesticides: cyclobutrifluram and isocycloseram. The prior administration had already approved a similar compound, fluazaindolizine, in 2023. While many scientists and international bodies treat any organic compound with at least one fully fluorinated carbon as a PFAS, EPA has maintained that these compounds do not meet its working definition of PFAS. In response to the controversy, EPA created a dedicated webpage explaining how it classifies PFAS and regulates pesticides containing potentially harmful compounds. 

EPA DECIDES NOT TO UPEND THE WASTE MANAGEMENT INDUSTRY – YET  

That’s quite a list of actions in a year that was effectively only about half as long as a standard regulatory year, given the regulatory freeze pending review and the extended shutdown. That said, it is also clear there were paths EPA could have pursued but chose to postpone or steer around. For many in the PFAS world, the Resource Conservation and Recovery Act (RCRA) sits at the top of that list. 

The proposal to list nine specific PFAS as RCRA hazardous constituents was first published in the Federal Register on February 8, 2024. If finalized, this would formally list certain PFAS and PFAS-containing wastes as hazardous wastes under Subtitle C, triggering cradle-to-grave management, manifesting, and strict treatment and disposal obligations across the waste management industry. Such a move would dramatically impact the waste management industry by forcing generators, transporters, landfills, and treatment facilities to handle PFAS more like classic hazardous constituents, with significant implications for permitting, liability, cost, and the viability of common practices like co-disposal and combustion. 

Although EPA did not act on the proposal, the agency did not rescind it either. EPA’s Unified Agenda lists the February 2024 proposal with an updated finalization date of April 2026. The only other significant mention of the RCRA proposal that we’re aware of was the commitment in the April release to “Determine how to better use RCRA authorities to address releases from manufacturing operations of both producers and users of PFAS.”  

OTHER AGENCY ACTIONS 

 While the current administration hasn’t been pushing the “all of government” message quite as aggressively, a couple additional federal agencies played a significant role in 2025. 

Department of Defense (DOD) – Albeit slower than some would have liked, the DOD continued to carry out earlier NDAA requirements to phase out PFAS-containing aqueous film-forming foam (AFFF), investigate PFAS contamination at and around military installations, and provide alternative drinking water where necessary. In 2025, DOD’s focus also shifted from primarily site discovery to long-term remedial design and interim mitigation, including expanded use of GAC and ion-exchange treatment for off-base private wells near training areas. 

As expected, The 2026 National Defense Authorization Act (NDAA) was also signed into law in December. Although an act of Congress, this bill largely focuses on the PFAS-related responsibilities of the DOD. The 2026 version includes several PFAS-related mandates, including: 

• More detailed, publicly accessible information about cleanup status and plans by location. 

• Accelerated PFAS investigation and remediation at contaminated military and former military sites.  

• The provision of alternative drinking water options (such as bottled water, filtration systems, or connection to public systems) for households whose private wells are contaminated with PFOS and PFOA from DOD activities 

The phaseout deadline for aqueous film-forming foam (AFFF) was also extended to October 1, 2026, and the contamination threshold changed from “in excess of one part per billion” to any “detectable” level of certain fluorinated substances. 

Lastly, the ban on the procurement of firefighter personal protective equipment (PPE) containing intentionally added PFAS was replaced by a performance- and content-based standard tied to the latest National Fire Protection Association (NFPA) 1970 standard.  

Food and Drug Administration (FDA) – In 2025, the FDA built on earlier actions that had already led many manufacturers to voluntarily phase out certain PFAS from food-contact materials, including paper and paperboard packaging. Agency communications and guidance in 2025 emphasized ongoing migration studies for short-chain PFAS and encouraged additional voluntary transitions away from PFAS-treated food packaging, especially in quick-service restaurant and bakery applications. 

In late 2025, the agency also released data from two studies on PFAS in the sectors under its watch: 

• Total Diet Study – On December 19, the FDA announced testing results from six additional Total Diet Study (TDS) regional collections, reporting that 92.8% of 542 food samples had no PFAS detections, and 7.2% showed only trace levels. The FDA continues expanding its methods to measure up to 30 PFAS across a wide range of food categories and has now tested more than 1,900 samples. Overall, PFAS have not been detected in 95% of the 1,352 fresh and processed foods tested since 2019.  

To learn more about analyzing PFAS in food, watch our webinar: Navigating the Complexities of Testing PFAS in Plant and Animal Tissue. 

• PFAS in Cosmetics – As required under the Modernization of Cosmetics Regulation Act of 2022, the FDA released its report on the safety of PFAS in cosmetics on December 29, 2025. In this study, the agency examined 51 PFAS used in 1,744 cosmetic formulations, closely evaluating the 25 most frequently used PFAS that constitute about 95% of intentionally added PFAS in cosmetics. Ultimately, the agency concluded that five compounds appeared to present low-level safety concerns and one showed a potential safety concern with significant remaining uncertainty, but that there was still insufficient toxicological data to determine the overall safety of most of the PFAS evaluated. 

CONGRESSIONAL PFAS REGULATORY ACTIVITY 

Congress talked a lot about PFAS in 2025, but surprisingly few PFAS bills were submitted. In fact, five of the seven (not counting the 2026 NDAA) weren’t introduced until December. Here’s a quick snapshot: 

PFAS National Drinking Water Standard Act of 2025 (H.R. 4168) – Would codify EPA’s PFAS National Primary Drinking Water Regulation into statute, locking in the federal MCLs for six PFAS (including PFOA and PFOS) so they could not be easily weakened or rescinded by future administrations. 

Water Systems PFAS Liability Protection Act (H.R. 1267) – Aims to provide CERCLA liability protections to “passive receivers” such as drinking water and wastewater utilities that receive PFAS in the normal course of providing services, shielding them from being treated like primary polluters for Superfund cost recovery. 

Relief for Farmers Hit with PFAS Act (H.R. 6476 / S. 3353) – Reintroduced on December 4, 2025, this bill authorizes grants to states to assist PFAS-impacted farmers, support testing and monitoring, fund remediation, and creates a USDA task force to coordinate PFAS-related assistance programs. 

PFAS Research and Development Reauthorization Act (H.R. 6667) – Reintroduced December 11, 2025, H.R. 6667 extends the authorization of appropriations for federal PFAS research and development activities. 

Clean Water Standards for PFAS Act (H.R. 6668 / S. 3457) – Also announced December 11, 2025, this bicameral bill would require EPA to develop PFAS water quality criteria and effluent limitation guidelines (ELGs) for multiple industry sectors and provide federal support for municipal water infrastructure upgrades. 

No Taxation on PFAS Remediation Act (H.R. 6669) – Introduced December 11, 2025, this bill would exempt from federal income taxes certain reimbursements or rebates individuals receive to clean up PFAS contamination where there is no municipal water service. 

PFAS Accountability Act (H.R. 6626 / S. 3460) – Reintroduced December 11, 2025, this bicameral bill would amend TSCA to create a federal cause of action for PFAS exposure and allow courts to award medical monitoring for affected individuals. 

THE WILD WEST LIVES ON 

In hindsight, 2025 was a chaotic mix of revised standards, policy debates, shifting expectations, new initiatives, and headline-grabbing controversies. One thing seems certain: 2026 will bring more of the same, with PFAS decisions touching nearly every corner of environmental stewardship, compliance, and capital planning. 

In this kind of environment, having reliable data and a solid technical foundation matters just as much as tracking the latest regulatory development. The Pace® PFAS team partners with clients on monitoring, method selection, treatability studies, technology evaluation, and regulatory strategy so you can turn a rapidly evolving landscape into practical, defensible next steps. Contact us to learn more about how Pace® can help.