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ARTICLE · 09 OCTOBER 2025

EPA's PFAS Rulemaking Trajectory: Key Updates Across CERCLA, TSCA, RCRA, SDWA And CWA

Holland & Knight
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The U.S. Environmental Protection Agency (EPA) is retaining its Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) designations for perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA) and plans to propose a new framework to guide future designations with economic impact considerations.

United StatesEnvironment
Michal I. Freedhoff
Michal I. Freedhoff
Dianne Phillips
Dianne Phillips
Meaghan Hembree
Meaghan Hembree
Dimitrios Karakitsos
Dimitrios Karakitsos
Aaron Aber
Aaron Aber
Molly Broughton
Molly Broughton
Amy Edwards
Amy Edwards
Nicholas Targ
Nicholas Targ
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Highlights

  • The U.S. Environmental Protection Agency (EPA) is retaining its Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) designations for perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA) and plans to propose a new framework to guide future designations with economic impact considerations.
  • With a targeted regulatory approach, the agency aims to narrow the scope of drinking water regulations to PFOS and perfluorooctanoic acid PFOA only.
  • The recently released Unified Regulatory Agenda outlines seven upcoming actions related to per- and polyfluoroalkyl substances (PFAS) at varying stages in the rulemaking process and utilizes a broad range of legislative authorities.

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