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ARTICLE · 24 FEBRUARY 2026

Federal PFAS Regulation: 2025 Activities And 2026 Anticipated Actions

Bryan Cave Leighton Paisner
Bryan Cave Leighton Paisner
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Bryan Cave Leighton Paisner

Bryan Cave Leighton Paisner

UK 2026 Chambers Firm Profile Bryan Cave Leighton Paisner (BCLP) is an international, fully...

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Now that we have entered the second year of Administrator Zeldin's tenure, BCLP looks back at EPA's actions in 2025 and previews what regulated industry may expect in 2026.

United StatesEnvironment
Erin L. Brooks
Erin L. Brooks
Christian Bromley
Christian Bromley
Bryan E. Keyt
Bryan E. Keyt

Now that we have entered the second year of Administrator Zeldin's tenure, BCLP looks back at EPA's actions in 2025 and previews what regulated industry may expect in 2026. The timeline below highlights the regulatory changes BCLP monitored throughout 2025, and those items companies should continue to watch in 2026.

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2025 EPA Actions

PFOA and PFOS Remain Designated under CERCLA

EPA retained the rule designating perfluorooctanoic acid ("PFOA") and perfluorooctanesulfonic acid ("PFOS") as "Hazardous Substances" pursuant to section 102(a) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 ("PFAS CERCLA Rule").

As discussed in BCLP's Insight, the PFAS CERCLA Rule affects businesses in many different ways, including Phase I Environmental Site Assessments; impacting Potentially Responsible Party determinations; enabling site reopeners or modifications; administering reporting requirements; subjecting PFOA and PFOS to the

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