The EPA has been busy over the past several months. The agency has taken the axe to many of its previously planned PFAS regulations while delaying others. The rescissions are further prompting states to legislate PFAS standards more stringent than the federal government’s. A recent Ballard Spahr memo summarizes the latest developments:
- EPA’s Comprehensive PFAS Strategy, announced May 18, 2026, retains the 4 ppt drinking water standards for PFOA and PFOS, proposes rescinding standards for four other PFAS (PFHxS, PFNA, HFPO-DA, and Hazard Index mixtures), and extends compliance deadlines to 2031.
- Submissions under the TSCA PFAS Reporting Rule have been delayed again and are set to include the November 2025 proposed amendments, including exemptions for imported articles, de minimis concentrations, byproducts, and research and development (R&D).
- EPA released updated PFAS Destruction and Disposal Guidance in April 2026, highlighting EPA’s preferred destruction techniques while continuing to express concerns about incomplete destruction, and committed to annual guidance updates.
- States are accelerating PFAS regulation, with Maine and Minnesota proceeding toward near-total product bans by 2032, at least 11 states now regulating AFFF, and states such as New York developing their own soil remediation standards.
- The retention of 4 ppt drinking water standards for PFOA and PFOS, combined with the unchanged Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substance designations, means that liability exposure remains significant for PFOA and PFOS.
PFAS regulations aren’t going away. Instead, companies need to be prepared to comply with PFAS regulations on a state-by-state level. While federal regulations are still slated to take effect, the extended deadlines and watered-down categories make it likely that states will lead in PFAS reduction.
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