January 15, 2026
While 2024 was a prolific year at the U.S. Environmental Protection Agency (EPA) for actions to address per- and polyfluoroalkyl substances (PFAS), the change in administration in 2025 resulted in a slowing, if not reversal, of PFAS actions.
PFAS are a class of thousands of chemicals that are water-, oil-, and heat-resistant, and have been produced and used since the 1940s in countless consumer and industrial products. The resilient characteristics of these compounds have led to their widespread use in products including cosmetics, water- and stain-resistant clothing, carpets, plastics, firefighting foam, and much more. PFAS exposure has been linked to a number of health concerns, including certain cancers, thyroid issues, liver and heart impacts, and developmental impacts in infants and children.
EPA has been investigating the occurrence of PFAS in the environment and their toxicological effects for decades, and in recent years has issued regulations, guidance, and policies aimed at further understanding and mitigating PFAS contamination in air, land, and water. While addressing PFAS contamination remains an agency priority on paper, the entry of the second Trump Administration has brought the broader deregulatory agenda to bear with PFAS as it has in other areas.
Below is a summary of some of the most significant actions EPA took in 2025 regarding PFAS. For more detail on the listed actions, click the hyperlink in the date to view our blog post on that topic.
January
- January 3: EPA announced the addition of nine PFAS to the Toxics Release Inventory for reporting year 2025.
- January 15: EPA published a “Draft Sewage Sludge Risk Assessment for Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonic Acid (PFOS).”
April
- April 28: EPA issued a press release announcing Administrator Lee Zeldin’s plans for addressing PFAS.
May
- May 13: EPA extended the reporting period for its Toxic Substances Control Act (TSCA) PFAS rule.
- May 14: EPA announced plans to roll back PFAS drinking water regulations.
September
- September 11: EPA filed a motion for partial vacatur in American Water Works Association et al. v. EPA requesting that the Court vacate the parts of its PFAS drinking water rule that finalize a regulatory determination and set maximum contaminant level goals and enforceable maximum contaminant levels for four of the six PFAS regulated under the original drinking water rule: PFHxS, PFNA, HFPO-DA, and PFBS.
- September 17: EPA announced that it intends to retain and defend in litigation its designation of PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act.
November
- November 13: EPA proposed reductions to PFAS reporting requirements under TSCA Section 8(a)(7).
In contrast to the renewed conservative federal landscape on PFAS, states are moving full force ahead on addressing the class of compounds. Many states, like Maine, Minnesota, and New Mexico, have established comprehensive bans on PFAS in consumer products. Many of these restrictions went into effect on January 1, 2025, and more are slated to go into effect in coming years. States have also set cleanup levels for remediation of and prohibitions on releases of PFAS into environmental media. Staying apprised of state actions in this area will be key in understanding the overall PFAS regulatory landscape.
Visit our blog for updates on these topics and more as the new year unfolds.