In April of 2025, the DoD issued a report on the status of PFAS Preliminary Assessments and Site Inspections. As of September 30, 2024, 722 sites required a PA/SI for PFAS, and 712 were completed. No further action was determined at 131 sites, and 574 needed to proceed to the Remedial Investigation and Feasibility Study phase of the CERCLA process. Appendix A of the report lists the facilities under investigation.
In an April 28 press release, the USEPA indicated that the new administration will implement several measures in accordance with the previous administration (i.e., designation of an EPA PFAS lead, creation of effluent limitations guidelines [ELGs] for certain PFAS, initiatives to engage with Congress and industry to establish a clear liability framework that focuses on the “polluter pays”). While not an exhaustive accounting of all measures the EPA plans within the coming years, some notable mentions include more frequency updates (annual) to the PFAS Destruction and Disposal Guidance, ELGs for PFAS manufacturers and metal finishers (with a consideration for other ELGs), evaluate the use of RCRA authorities to address releases from manufacturing operations of both producers and users of PFAS, and finish the public comment period for biosolids risk assessment and determine path forward based on comments.
The public comment period on the 2024 Draft PFAS Human Health Water Quality Criteria (HHC) for PFOS, PFOA and PFBS was extended to April 29, 2025 but has subsequently closed.
Comments are variable; some entities are requesting that the EPA develop ambient water quality criteria for additional PFAS (the entire class of PFAS or, at the least, for those PFAS for which published toxicity assessments or lifetime health advisories exist) and states be provided with a methodology to calculate alternate criteria for more exposed communities (e.g., subsistence fishing populations). Other commenters, including states, criticize the draft PFAS HHC as being below detectable thresholds and emphasize that source reduction is more cost effective. The HHC was not addressed in the EPA April 28 announcement on EPA actions to combat PFAS.
On May 14th, the USEPA announced that it intends to maintain the maximum contaminant levels (MCLs) for PFOS and PFOA and “rescind and reconsider” the MCLs for PFNA, PFHxS, and HFPO-DA (as well as the hazard index, which included PFBS when more than 1 PFAS were present). The announcement also came with an extension to the compliance deadline (until 2031) that is planned to be part of a proposal rule in Fall of 2025, with finalization planned in Spring of 2026. The announcement comes during D.C. Circuit granted stays of two existing lawsuits against the USEPA regarding the MCLs and the Final Designation of PFOA and PFOS as Hazardous Substances under CERCLA.
On May 29, 2025, Congress “re-introduced” legislation to ensure U.S. Military Veterans who were exposed to PFAS are provided with appropriate medical care. The bill does not suggest there is sufficient medical evidence to conclude that illnesses or medical conditions are attributable to exposure to PFAS, but it does list six conditions previously suggested to have a “
probable link” to exposure to PFOA.
On May 30, 2025, a re-opened comment period for a January 23, 2024 proposed rule (Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources: Large Municipal Waste Combustors (89 FR 4243) closed with a total comment period of 6.5 months. Of note was one set of
comments issued from the New England-based Conservation Law Foundation that specifically requests the EPA to evaluate municipal waste combustors PFAS emissions associated with burning municipal waste. PFAS are not currently considered Hazardous Air Pollutants and therefore are not regulated under air laws; however, an increasing body of research is suggesting that specific conditions are necessary to achieve adequate destruction. Most municipal waste combustors do not operate at the specific conditions to achieve adequate destruction of PFAS and products of incomplete destruction (PIDs) are a serious concern. Air emissions of PFAS appear to be a focus of
EPA’s Actions to Combat PFAS.
On June 10, 2025, a group of 20 internationally recognized PFAS-experts submitted a Scientists’ Statement on the chemical definition of PFAS. In summary, this panel of experts endorse the Organization for Economic Co-operation and Development (OECD) 2021 definition of PFAS, including a single carbon saturated with fluorines (i.e., C1). There is considerable debate within regulatory agencies as to whether C1 classifies as a PFAS; however, the scientists make a clear distinction between the chemical definition of the class of compounds and what percentage of those compounds end up being regulated. The statement is not a plea to regulate all PFAS, but rather a factual statement defining PFAS chemistry.
Delaware
has joined California by introducing legislation to essentially adopt the maximum contaminant levels (MCLs) that the EPA established in April 2024. In early June, the Delaware state senate passed State Bill 72, which establishes a website and requires drinking water municipalities to notify the public if the MCLs are exceeded. The purpose of the legislation appears to be accelerating reporting of PFAS results to the public so that the public may advocate for safer water prior to 2031 (the new deadline for compliance with 4 nanograms per liter for PFOA and PFOS). The legislation does not include penalties for exceeding the April 2024 MCLs and appear to rely on public advocacy to compel water companies to mitigate exceedances.
With PFOA and PFOS presently 
characterized as Hazardous Substances under CERCLA, the implications of including PFOA and PFOS under All Appropriate Inquiries for Phase I and Phase II of Environmental Site Assessments is causing confusion with respect to land application of biosolids. The confusion partially stems from
H.R. 1267 (Feb 2025), which attempts to exempt water management entities (i.e., “passive receivers” of PFAS) from PFOA and PFOS discharges under CERCLA, and
CERCLA Section 101(22)(D), which excludes the “normal” application of fertilizer from a CERCLA defined release. However, a
2019 legal decision may provide precedent that hazardous substances within the fertilizer do not fit the CERCLA exemption.
