EPA Will Retain CERCLA Hazardous Substance Designation For PFOA, PFOS, Will Develop CERCLA Section 102(a) Framework Rule

The U.S. Environmental Protection Agency (EPA) announced on September 17, 2025, its next steps regarding regulatory efforts to address cleanup of perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS). On May 8, 2024, EPA designated PFOA, PFOS, and their salts and structural isomers as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Under the rule, entities are required to report immediately releases of PFOA and PFOS that meet or exceed the reportable quantity (RQ) of one pound within a 24-hour period to the National Response Center (NRC), state, Tribal, and local emergency responders. In its September 17, 2025, announcement, EPA states that it is retaining the CERCLA hazardous substance designation for PFOA and PFOS and intends to develop a CERCLA Section 102(a) Framework Rule going forward. According to EPA, the Framework Rule "will provide a uniform approach to guide future hazardous