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ARTICLE · 24 DECEMBER 2025

EPA's PFAS CERCLA Designation And Its Impact On EPA Brownfields Grant Funding

Holland & Knight
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The U.S. Environmental Protection Agency (EPA) recently answered questions related to the designation of two per- and polyfluoroalkyl substances (PFAS)...

United StatesEnvironment
Amy Edwards
Amy Edwards
Ed Callaway
Ed Callaway
Dianne Phillips
Dianne Phillips
Michael Galano
Michael Galano
Alexandra E. Ward
Alexandra E. Ward
Maggie P. Pahl
Maggie P. Pahl
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Highlights

  • The U.S. Environmental Protection Agency (EPA) recently answered questions related to the designation of two per- and polyfluoroalkyl substances (PFAS) – perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) – as Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substances.
  • The published FAQs also explain that EPA Brownfields Grant recipients are required to demonstrate they cannot be held potentially liable for PFOA or PFOS contamination under CERCLA Section 107.
  • This Holland & Knight alert explores how the EPA's designation will impact how EPA Brownfields Grants can be used to address PFAS contamination.

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