By Jack Sheldon
Key Takeaways: EPA PFAS Regulations in 2026
- EPA expanded PFAS monitoring, testing methods, and drinking water implementation efforts, including outreach to public water systems under the PFAS OUT Initiative.
- The U.S. Court of Appeals upheld 2024 drinking water standards, maintaining 10 ppt MCLs for PFNA, HFPO-DA (GenX chemicals), PFHxS, and PFBS.
- EPA reaffirmed use of existing authorities, including TSCA, CERCLA, and the Safe Drinking Water Act, to address PFAS contamination, reporting, and site cleanup.
- The agency emphasized testing, remediation, and regulatory implementation, while broader consumer exposure reduction strategies and expanded toxicity research remain areas to watch.
The U.S. Environmental Protection Agency (EPA), under Administrator Lee Zeldin, has released a summary of actions taken during the first year of the Trump Administration to address risks associated with per and polyfluoroalkyl substances (PFAS). The update reflects an emphasis on testing and detection, drinking water protection, site cleanup, regulatory implementation, enforcement, and coordination with states, tribes, local governments, and federal partners.
According to EPA, addressing PFAS contamination was identified as a priority at the outset of the Administration, with the agency focusing on identifying PFAS, preventing further contamination of drinking water, remediating impacted sites, and pursuing accountability where contamination has occurred.
EPA’s PFAS Policy Priorities in 2026
EPA characterizes its PFAS approach as relying upon:
- Expanded monitoring and testing capabilities
- Direct support to impacted communities
- Use of existing statutory authorities, including TSCA, SDWA, CERCLA, and the Clean Water and Clean Air Acts
- Continued development of treatment and disposal guidance
- Coordination across EPA program offices and regions
EPA PFAS Actions in the First Year of the Trump Administration
Since January 2025, EPA has reported the following actions related to PFAS:
Drinking Water and Community Support
- Launch of the PFAS OUTreach Initiative (PFAS OUT) to engage public water systems requiring upgrades to address PFAS, including PFOA and PFOS.
- Release of $945 million to reduce PFAS exposure in drinking water.
- Installation of point-of-entry treatment systems, private well sampling, and bottled water provision at several sites
- Completion of PFAS treatment systems serving households in southern California water districts.
Regulatory and Enforcement Developments
- Advancement of science-based levels for PFOA and PFOS under the National Primary Drinking Water Regulations, with revised compliance timelines. =
- Judicial denial of EPA’s request to vacate the 2024 PFAS drinking water rule, leaving in place 10 ppt MCLs for PFNA, HFPO-DA (GenX chemicals), PFHxS, and PFBS.
- Affirmation of the CERCLA hazardous substance designation for PFOA and PFOS.
- Proposal of revisions to TSCA PFAS reporting requirements intended to reduce duplicative reporting while maintaining access to use and safety information.
- Finalization of a consent order requiring removal of PFAS firefighting foam and system cleaning at Brunswick Executive Airport in Maine.
Expanded PFAS Testing, Research, and Methods Development
- Development of a laboratory method capable of detecting 40 PFAS compounds across multiple media, including water, soil, sediment, landfill leachate, and fish tissue.
- Expanded PFAS sampling of private wells, public water systems, and Tribal drinking water systems in multiple EPA Regions.
- Provision of interim PFAS laboratory certification for Alaska’s Department of Environmental Conservation.
Site-Specific and Federal Facility Actions:
- PFAS sampling and response actions near military installations, including Joint Base Lewis McChord, Fort Bragg, and the McAlester Army Ammunition Plant.
- Continued response actions at Superfund sites with PFAS impacts, including activities in New Jersey.
PFAS Disposal and Treatment Guidance
- Shift to annual updates of EPA’s PFAS Destruction and Disposal Guidance to reflect evolving treatment technologies and effectiveness data.
EPA Coordination and Legal Authorities
EPA has indicated it is establishing a cross agency coordinating group, supported by the Office of the Administrator and the Office of Water, to align PFAS research, regulatory actions, and cleanup efforts across program offices and regions.
EPA’s PFAS response relies on existing statutory authorities to:
- Regulate new and existing chemicals under TSCA
- Establish and enforce drinking water standards under the Safe Drinking Water Act
- Address contaminated sites under CERCLA and other cleanup authorities
- Control industrial discharges and emissions under the Clean Water Act
Testing Framework
EPA emphasized continued reliance on validated laboratory methods, including both targeted and non-targeted PFAS testing, to guide regulatory and cleanup decisions. The agency currently employs multiple methods for testing PFAS in drinking water, surface water, wastewater, solids, and air, and is continuing to develop air testing methodologies.
PFAS Policy Outlook: What to Expect Next from EPA
EPA framed these actions as building on PFAS initiatives undertaken during President Trump’s first term, including the 2019 PFAS Action Plan and related regulatory determinations for PFOA and PFOS.
Looking ahead, EPA states it plans to further expand PFAS testing programs, support development of new treatment technologies, increase community outreach, and continue enforcement activities in coordination with state, tribal, and local partners.
While the first-year summary highlights significant activity in testing, drinking water protection, and site response, it provides limited detail regarding broader strategies to reduce consumer exposure to PFAS in products or to expand federal funding for toxicity research beyond PFOA, PFOS, and their precursors. Continued evaluation of the health effects of additional PFAS compounds and pathways of exposure may influence future regulatory and risk management priorities.
Compliance Considerations for Regulated Entities
EPA’s first year PFAS actions under the Trump Administration signal continued federal attention to PFAS across drinking water, site cleanup, chemical reporting, and disposal practices. While many initiatives build on existing authorities rather than creating new statutory requirements, regulated entities should consider the following compliance implications:
Drinking Water Systems
Public water systems should anticipate:
- Increased EPA outreach and engagement through initiatives such as PFAS OUT, particularly for systems detecting PFOA or PFOS.
- Continued focus on implementation of National Primary Drinking Water Regulations for PFOA and PFOS, including revised compliance timelines.
- Greater scrutiny of monitoring data as EPA expands PFAS testing methods and sampling efforts.
Systems identifying PFAS above applicable standards should be prepared for potential technical assistance discussions, treatment upgrades, or other corrective measures.
Site Owners, Operators, and Potentially Responsible Parties
Entities associated with PFAS impacted properties should note:
- EPA’s affirmation of the CERCLA hazardous substance designation for PFOA and PFOS reinforces the agency’s ability to pursue response actions and cost recovery.
- Increased use of site-specific enforcement tools, including consent orders, particularly where PFAS sources are identified.
- Expanded testing methods may result in broader detection of PFAS across media, potentially affecting site characterization and remedial strategies.
Property owners, developers, and operators should continue to evaluate PFAS risks in environmental due diligence and remediation planning.
Manufacturers, Importers, and Users of PFAS
Companies subject to the Toxic Substances Control Act (TSCA) should monitor:
- Proposed revisions to PFAS reporting requirements intended to reduce duplicative submissions while preserving EPA’s access to use and safety information.
- Continued expectations that regulated entities provide accurate chemical use and exposure data when required.
Even where reporting burdens are adjusted, EPA has emphasized maintaining visibility into PFAS manufacturing, processing, and use.
Industrial Facilities and Waste Handlers
Facilities managing PFAS containing waste or discharges should be aware of:
- More frequent updates to EPA’s PFAS Destruction and Disposal Guidance, now issued annually.
- Ongoing evaluation of treatment technologies, which may influence acceptable disposal practices over time.
- Potential implications for air, water, and waste permitting as EPA advances PFAS testing methods across environmental media.
Tribal, State, and Local Coordination
Entities operating in coordination with states, tribes, or local governments may see:
- Increased data sharing and sampling activity, particularly where EPA is supporting community or Tribal drinking water systems.
- Greater alignment between federal and nonfederal authorities as EPA emphasizes cooperative federalism in PFAS response efforts.
Steps to Stay Ahead on PFAS Compliance
Given EPA’s stated direction, regulated entities may wish to:
- Review existing PFAS monitoring, reporting, and response practices for alignment with current EPA guidance.
- Track evolving PFAS testing methodologies that could affect detection thresholds and compliance expectations.
- Assess potential CERCLA exposure where historical or ongoing PFAS use may be implicated.
- Incorporate PFAS considerations into environmental management systems, transactions, and long-term compliance planning.
Conclusion: Continued Regulatory Momentum and Growing Complexity
EPA’s first-year PFAS actions reflect continued federal engagement using existing statutory authorities to address drinking water contamination, site cleanup, chemical reporting, and disposal practices. The agency’s emphasis on testing, implementation, and enforcement reinforces that PFAS remains a priority regulatory issue.
At the same time, ongoing litigation, evolving science, and expanding state-level requirements contribute to an increasingly complex compliance landscape. For regulated entities operating across jurisdictions, understanding where federal, state, and international PFAS obligations intersect is becoming essential to risk management and long-term planning.
Stay Ahead of Evolving PFAS Requirements
PFAS regulations continue to expand across federal, state, and international jurisdictions, creating new compliance and risk management challenges for regulated entities.
Stay ahead of global PFAS developments with our PFAS Regulatory Dashboard. This interactive tool consolidates more than 1,200 current PFAS requirements across 50 countries and 48 U.S. states, helping organizations understand where and how obligations apply.
Explore the free version for broad regulatory visibility, or reach out to our team to get a subscription for deeper insights.
