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2 December 2025

EPA Poised To Approve Incineration As PFAS Destruction Method In Upcoming Guidance

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Shook, Hardy & Bacon

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The U.S. Environmental Protection Agency (EPA) is preparing to update its Interim Guidance on the destruction and disposal of per- and polyfluoroalkyl substances (PFAS) and PFAS-containing materials.
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The U.S. Environmental Protection Agency (EPA) is preparing to update its Interim Guidance on the destruction and disposal of per- and polyfluoroalkyl substances (PFAS) and PFAS-containing materials. According to a September EPA report, hazardous waste incineration can achieve near-complete destruction of PFAS compounds. Destruction and removal efficiencies ranged from 99.95% to 99.9999%, with low to non-detectable emissions of volatile fluorinated compounds, positioning incineration as a viable option for managing PFAS waste. EPA's Interim Guidance is expected in spring 2026.

While EPA cannot endorse a specific treatment method, its forthcoming guidance will incorporate these findings, signaling that incineration may be considered effective under appropriate conditions. The agency stresses that site-specific validation remains essential to confirm performance and prevent formation of products of incomplete destruction.

This development is particularly significant for entities managing PFAS waste under The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), which now designates PFOS and PFOA as hazardous substances. Effective destruction methods can help mitigate long-term liability risks. EPA is also expected to release the results of additional PFAS studies, including research on municipal waste-to-energy facilities, in early 2026.

States have also begun exploring PFAS incineration as a potential disposal method. The State of Washington recently opted to incinerate PFAS-containing firefighting foam after evaluating alternatives. However, environmental groups continue to raise concerns about incomplete destruction and residual contamination.

EPA's updated guidance will provide the latest scientific information on PFAS destruction technologies, including incineration, but will not impose regulatory requirements. Stakeholders should monitor these developments closely and consider whether incineration should be integrated into PFAS waste management strategies, subject to facility-specific testing and compliance with RCRA.

For more details, see EPA's PFAS destruction report titled "PFAS Destruction by a Hazardous Waste Incinerator: Testing Results."

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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