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ARTICLE · 20 MAY 2025

When States Step In: PFAS Policy Innovation Or Fragmentation?

Bergeson & Campbell
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Per- and polyfluoroalkyl substances (PFAS) remain a top concern for regulators and the public alike. While federal regulators continue to lay the groundwork for a comprehensive response...

United StatesEnergy and Natural Resources
L. Claire Hansen
L. Claire Hansen
Carla Hutton
Carla Hutton
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Per- and polyfluoroalkyl substances (PFAS) remain a top concern for regulators and the public alike. While federal regulators continue to lay the groundwork for a comprehensive response, including through the PFAS Strategic Roadmap, states are increasingly positioning themselves as policy innovators in this space. The recent announcement that the U.S. Environmental Protection Agency (EPA) will issue additional guidance and extend the compliance deadline for the Toxic Substances Control Act (TSCA) Section 8(a)(7) PFAS reporting rule underscores a broader dynamic: in the absence of fast-moving federal action that states perceive as comprehensive, states are setting the pace, even if their approaches do not always (or ever) mirror the federal approach to regulation and risk mitigation.

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