Article
D.C. Circuit Upholds EPA’s Designation Of PFOA And PFOS As CERCLA “hazardous Substances”
The U.S. Court of Appeals for the D.C. Circuit has upheld EPA's designation of PFOA and PFOS as hazardous substances under CERCLA, rejecting industry challenges on statutory interpretation, notice requirements, and cost-benefit analysis grounds. This landmark decision opens the door to widespread CERCLA liability for PFAS contamination and potentially paves the way for additional PFAS compound designations, fundamentally reshaping environmental cleanup obligations across industries.
Hogan Lovells Cadwalader