Federal PFAS Regulation And Litigation: Developments, Implementation, And What To Expect In The Second Year Of The Trump Administration

Over the last two years, there has been a flurry of activity at the federal level related to the regulation of PFAS. In 2024, the Biden EPA finalized significant PFAS rulemakings under the Safe Drinking Water Act (SDWA) and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), proposed regulations under the Resource Conservation and Recovery Act (RCRA), issued a significant guidance document on PFAS waste disposal and water quality criteria, and continued major PFAS data collection and disclosure efforts under the Clean Water Act (CWA), SDWA, Toxic Substance Control Act (TSCA), and Emergency Planning and Community Right-to-Know Act (EPCRA).

As the Trump Administration took office in 2025, major questions hung over the fate of these regulatory and data collection efforts. In many respects, the Trump Administration has moved forward with PFAS regulation, but with relaxed deadlines and reduced requirements.