While widespread PFAS regulatory rollbacks were expected following the administration change in 2025, the federal strategy has not led to the anticipated deregulations.
The current U.S. Environmental Protection Agency (EPA) has adjusted certain timelines, but it has not abandoned its foundational PFAS regulatory framework—particularly regarding the Resource Conservation and Recovery Act (RCRA) and drinking water standards.
Hazardous Waste under RCRA
It is expected that EPA will proceed with its plan to regulate nine specific PFAS compounds as hazardous constituents under RCRA by April 2026, a move that will trigger mandatory corrective action for releases.
Drinking Water Standards
Landmark EPA drinking water regulations were issued in 2024, establishing legally enforceable Maximum Contaminant Levels (MCLs) for six specific PFAS. These regulations are now being refined rather than eliminated. While EPA announced in May 2025 that it intends to rescind regulations for four PFAS substances and delay compliance for others until 2031, it explicitly kept the four parts-per-trillion (ppt) MCL in place for the most prevalent compounds, PFOA and PFOS. This approach indicates a shift toward a more targeted, potentially industry-friendly regulatory structure rather than absolute repeal. EPA continues to issue press releases and regulatory plans for drinking water standards, while the rule establishing MCLs remains subject to pending legal challenges from the industry, water associations, and chemical companies.
Hazardous Substances under CERCLA
EPA designated PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, also known as Superfund), effective July 2024. The CERCLA designation is heavily contested, with significant legal, political, and industry-driven pressures influencing the outcome; however, as of September 2025, EPA has indicated its intention to retain and defend the rule.
Key Takeaways
EPA’s actions suggest a balanced strategy—pushing forward with modified regulations rather than an overhauled approach. The administration is extending deadlines and reducing the immediate scope of regulated chemicals to address logistical concerns for water utilities, but it is continuing to classify PFAS as hazardous waste and allow EPA to clean up contaminated sites.
Chris Rose, PE, is an Associate in Langan’s Irvine office with over 20 years of environmental experience. His expertise includes environmental site assessments and remediation, water and wastewater design, solid waste management, and civil infrastructure design.