After addressing a number of other programs over the first 100 days of the new administration, on April 28, 2025, the Environmental Protection Agency (EPA) finally addressed PFAS. Administrator Lee Zeldin outlined a number of actions—old and new—aimed at manufacturers and importers of PFAS and PFAS-containing products with an emphasis on “sound science” and the need for more robust data on PFAS toxicity.
The announcement foreshadows a more risk-based review of PFAS by EPA, signaling that the Agency may be receptive to industry submissions regarding variances in toxicological profiles of different PFAS and open to regulating PFAS commensurate with their toxicity and the risk they present to human health and environment. EPA committed to rolling out a comprehensive PFAS Testing Strategy, which could include new data development and information-gathering obligations for companies dealing in PFAS-containing products. EPA will include several PFAS chemicals on the Toxic Release Inventory, triggering reporting obligations for manufacturers, processors and users of PFAS. The Agency also reaffirmed its commitment to enforcing the TSCA Reporting Rule, extinguishing lingering rumors of the rule's demise, although the Agency hinted at possible accommodations for small businesses and article importers.
Follow this space for updates on comment periods, reporting deadlines and emerging rules and guidance, as Zeldin indicated in his announcement that “this list is the first, not the last, of all decisions and actions EPA will be taking to address PFAS.”
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