ARTICLE
17 June 2025

PFAS Drinking Water Standards: State-by-state Regulations

The regulation of per- and polyfluoroalkyl substances ("PFAS") in drinking water remains one of the primary focuses for legislatures and agencies at both the state and federal levels.
United States Energy and Natural Resources

Summary

The regulation of per- and polyfluoroalkyl substances ("PFAS") in drinking water remains one of the primary focuses for legislatures and agencies at both the state and federal levels. In May 2025, the United States Environmental Protection Agency ("EPA") affirmed Maximum Contaminant Levels ("MCLs") of 4 parts per trillion ("ppt") for two PFAS substances, perfluorooctanoic acid ("PFOA") and perfluorooctane sulfonic acid ("PFOS"). Many states have already regulated PFAS compounds in drinking water but have done so in a variety of different ways and at different levels.

The result is a patchwork of regulations and standards which presents significant operational and compliance challenges to impacted drinking water systems. This client alert surveys MCLs, as well as guidance and notification levels, for PFAS compounds in drinking water across the United States.

Federal Actions

As discussed in BCLP's recent insight, on May 14, 2025, EPA announced that it would issue a proposed rule in fall 2025 to make several changes to the MCLs that it set in April 2024:

  • The most significant takeaways from EPA's anticipated rulemaking are:
    • The existing 4 ppt MCL for PFOA and PFOS will remain in place.
    • The MCLS for four other PFAS – PFHxS, PFNA, PFBS, and HFPO-DA – along with the Hazard index for combinations of these substances will be rescinded and possibly reconsidered.
  • The agency is also establishing a new technical assistance and outreach initiative for public water systems (in addition to continuing to offer the water technical assistance (WaterTA) service). EPA states that the new initiative, known as the PFAS OUTreach Initiative, or PFAS OUT, will prioritize outreach to public water systems in need of capital improvements to address PFAS impacts and will connect those utilities with "resources, tools, funding, and technical assistance" to position them to achieve compliance with the MCLs for PFOA and PFOS by the new deadline.
  • EPA hinted at "holding polluters accountable" and prioritizing enforcement against industrial sources of PFAS contaminating public water supplies, noting that "the need for a polluter pays model has guided a lot of the work to be done at EPA in the future."

For additional information, please refer to EPA's NPDWR April 2024 website and EPA's NPDWR Implementation website

State Regulations

The regulatory landscape for PFAS compounds in drinking water at the state level currently consists of an array of widely varying standards and regulations. For example, regulatory concentrations range from 0.0079 ppt (Minnesota; PFOA only) to 400,000 ppt (Michigan; PFHxA only), depending on the PFAS compounds, the nature of the regulation, and the state's determination as to which levels may result in health effects. The chart below illustrates the discrepancies between the regulatory levels for PFOA and/or PFOS.

1638356a.jpg

The map below and chart are current as of May 29, 2025, but this is a very active regulatory space, and additional state action is anticipated soon. For example, Florida, Illinois, and Virginia have enacted legislation to establish MCLs or statewide cleanup target levels for PFAS compounds for drinking water, so implementing regulations in these jurisdictions may be forthcoming. Additionally, several states, including Arizona, California, Delaware, Idaho, Indiana, and South Carolina, have proposed, but not yet promulgated, various types of drinking water regulations or rulemaking procedures for PFAS.

Notably, several states, including California, Connecticut, New York, Ohio, Pennsylvania, and Vermont, are proposing MCLs and other restrictions that, in part, adopt certain concentration values in EPA's original action from April 2024.

In this document, BCLP does not discuss the sampling protocol or testing requirements for Public Water Systems (PWS) in various states.

1638356b.jpg

States that have adopted a standard lower than 70 ppt

California

Concentration level

3 ppt (stated by the California Water Boards as 3 ng/L)

Chemical(s) and type of regulation

PFHxS (Notification)

Regulatory information

Regulation and related information

Concentration level

5.1 ppt (stated by the California Water Boards as 0.0000051 mg/L)

Chemical(s) and type of regulation

PFOA (Notification)

Regulatory information

Regulation and related information

Concentration level

6.5 ppt (stated by the California Water Boards as 0.0000065 mg/L)

Chemical(s) and type of regulation

PFOS (Notification)

Regulatory information

Regulation and related information

Connecticut

Concentration level

2 ppt

Chemical(s) and type of regulation

6:2 chloropolyfluoroether sulfonic acid (Notification)

Regulatory information

Action Level and related information

Concentration level

5 ppt

Chemical(s) and type of regulation

8:2 chloropolyfluoroether sulfonic acid (Notification)

Regulatory information

Action Level and related information

Concentration level

10 ppt

Chemical(s) and type of regulation

PFOS (Notification)

Regulatory information

Action Level and related information

Concentration level

12 ppt

Chemical(s) and type of regulation

PFNA (Notification)

Regulatory information

Action Level and related information

Concentration level

16 ppt

Chemical(s) and type of regulation

PFOA (Notification)

Regulatory information

Action Level and related information

Concentration level

19 ppt

Chemical(s) and type of regulation

Gen X or HFPO-DA (Notification)

Regulatory information

Action Level and related information

Concentration level

49 ppt

Chemical(s) and type of regulation

PFHxS (Notification)

Regulatory information

Action Level and related information

Delaware

Concentration level

4 ppt

Chemical(s) and type of regulation

PFOS and PFOA (Enforced but proposed MCLs)

Regulatory information

MCLs and Related Information

Concentration level

10 ppt

Chemical(s) and type of regulation

PFHxS, PFNA, and Gen X (Enforced but proposed MCLs)

Regulatory information

MCLs and Related Information

Hawaii

Concentration level

7.7 ppt, etc.[1] (stated by the Hawaii Department of Health as 0.0077 µg/L)

Chemical(s) and type of regulation

PFOS and 24 other PFAS substances (Guidance)

Regulatory information

Environmental Action Levels (Table D-3a) and Related Information

[1] Hawaii has 24 additional regulations, including the following: PFDA (7.7 ppt); PFOA, HFPO-DA, and PFNA (12 ppt); PFUnDA (19 ppt); PFDoDA and PFTrDA (26 ppt); PFHpS and PFDS (38 ppt); PFOSA (46 ppt); PFHpA and PFHxS (77 ppt); PFTeDA (260 ppt); PFPrA (510 ppt); ADONA (1,200 ppt); PFPeA and 6:2 FTS (1,500 ppt); PFHxA and 6:2 FTTAoS (1,900 ppt); PFPeS (2,500 ppt); 8:2 FTOH (4,200 ppt); 6:2 FTOH (6,000 ppt); PFBS (7,300 ppt); and PFBA (15,000 ppt).

Illinois

Concentration level

2 ppt (stated by the Illinois Environmental Pollution Control Agency as 2 ng/L)

Chemical(s) and type of regulation

PFOA (Guidance)

Regulatory information

Regulation and related information

Concentration level

14 ppt (stated by the Illinois Environmental Pollution Control Agency as 14 ng/L)

Chemical(s) and type of regulation

PFOS (Guidance)

Regulatory information

Regulation and related information

Concentration level

21 ppt (stated by the Illinois Environmental Pollution Control Agency as 21 ng/L)

Chemical(s) and type of regulation

PFNA (Guidance)

Regulatory information

Regulation and related information

Maine

Concentration level

20 ppt (stated in the Interim Drinking Water Standard as 20 ng/L)

Chemical(s) and type of regulation

6 PFAS substances combined: PFOA, PFOS, PFHxS, PFNA, PFHpA, and PFDA (Notification)

Regulatory information

Interim Drinking Water Standard, 2024 Maine PFAS Drinking Water Report, and Related Information

Massachusetts

Concentration level

20 ppt (stated in the regulation as 20 ng/L)

Chemical(s) and type of regulation

6 PFAS substances combined: PFOA, PFOS, PFHxS, PFNA, PFHpA, and PFDA (MCL)

Regulatory information

Regulation and related information

Michigan

Concentration level

6 ppt

Chemical(s) and type of regulation

PFNA (MCL)

Regulatory information

Regulation and related information

Concentration level

8 ppt

Chemical(s) and type of regulation

PFOA (MCL)

Regulatory information

Regulation and related information

Concentration level

16 ppt

Chemical(s) and type of regulation

PFOS (MCL)

Regulatory information

Regulation and related information

Concentration level

51 ppt

Chemical(s) and type of regulation

PFHxS (MCL)

Regulatory information

Regulation and related information

Minnesota

Concentration level

0.0079 ppt

Chemical(s) and type of regulation

PFOA (Guidance)

Regulatory information

Health Advisory and related information

Concentration level

2.3 ppt

Chemical(s) and type of regulation

PFOS (Guidance)

Regulatory information

Health Advisory and related information

Concentration level

47 ppt

Chemical(s) and type of regulation

PFHxS (Guidance)

Regulatory information

Health Advisory and related information

Nevada

Concentration level

6.67 ppt (stated by the Nevada Division of Environmental Protection as .0667 µg/L)

Chemical(s) and type of regulation

PFSA (Guidance)

Regulatory information

Basic Comparison Levels

Related information

Concentration level

10 ppt (stated by the Nevada Division of Environmental Protection as .1 µg/L)

Chemical(s) and type of regulation

PFOA (Guidance)

Regulatory information

Basic Comparison Levels

Related information

New Hampshire

Concentration level

11 ppt

Chemical(s) and type of regulation

PFNA (MCL)

Regulatory information

Regulation and related information

Concentration level

12 ppt

Chemical(s) and type of regulation

PFOA (MCL)

Regulatory information

Regulation and related information

Concentration level

15 ppt

Chemical(s) and type of regulation

PFOS (MCL)

Regulatory information

Regulation and related information

Concentration level

18 ppt

Chemical(s) and type of regulation

PFHxS (MCL)

Regulatory information

Regulation and related information

New Jersey

Concentration level

13 ppt

Chemical(s) and type of regulation

PFNA and PFOS (MCL)

Regulatory information

Regulation and related information

Concentration level

14 ppt

Chemical(s) and type of regulation

PFOA (MCL)

Regulatory information

Regulation and related information

New York

Concentration level

10 ppt

Chemical(s) and type of regulation

PFOA and PFAS (MCL)

Regulatory information

Regulation and related information

North Carolina

Concentration level

10 ppt

Chemical(s) and type of regulation

GenX or HFPO-DA (Guidance)

Regulatory information

Health Advisory and related information

Ohio

Concentration level

4 ppt

Chemical(s) and type of regulation

PFOS and PFOA (Guidance)

Regulatory information

Statewide PFAS Action Plan

Concentration level

10 ppt

Chemical(s) and type of regulation

PFHxS, PFNA, and Gen X (Guidance)

Regulatory information

Statewide PFAS Action Plan

Pennsylvania

Concentration level

14 ppt

Chemical(s) and type of regulation

PFOA (MCL)

Regulatory information

Regulation and related information

Concentration level

18 ppt

Chemical(s) and type of regulation

PFOS (MCL)

Regulatory information

Regulation and related information

Rhode Island

Concentration level

20 ppt

Chemical(s) and type of regulation

6 PFAS substances combined: PFOA, PFOS, PFHxS, PFNA, PFHpA, and PFDA (Notification)

Regulatory information

Interim Drinking Water Standard and related information

Vermont

Concentration level

20 ppt (stated in the regulation as 0.000002 mg/L)

Chemical(s) and type of regulation

5 PFAS substances combined: PFOA, PFOS, PFHpA, PFHxS, and PFNA (MCL)

Regulatory information

Regulation and related information

Washington

Concentration level

9 ppt

Chemical(s) and type of regulation

PFNA (Notification)

Regulatory information

Code and related information

Concentration level

10 ppt

Chemical(s) and type of regulation

PFOA (Notification)

Regulatory information

Code and related information

Concentration level

15 ppt

Chemical(s) and type of regulation

PFOS (Notification)

Regulatory information

Code and related information

Concentration level

65 ppt

Chemical(s) and type of regulation

PFHxS (Notification)

Regulatory information

Code and related information

States that have adopted a standard equal to 70 ppt

Alaska

Concentration level

70 ppt

Chemical(s) and type of regulation

5 PFAS substances combined: PFOS, PFOA, PFNA, PFHxS, and PFHpA (Guidance)

Regulatory information

Action Level and related information

Colorado

Concentration level

70 ppt (stated in the regulation as 70 ng/L)

Chemical(s) and type of regulation

3 PFAS substances combined: PFOS, PFOA, and PFNA (Guidance)

Regulatory information

Translation Level and related information

New Mexico

Concentration level

70 ppt

Chemical(s) and type of regulation

PFOS, PFHxS and PFOA combined (Guidance)

Regulatory information

Toxic Pollutant Standard

Wisconsin

Concentration level

70 ppt

Chemical(s) and type of regulation

PFOS and PFOA combined (MCL)

Regulatory information

Regulation and related information

States that have adopted a standard higher than 70 ppt

California

Concentration level

500 ppt (stated (stated by the California Water Boards as as 0.0005 mg/L)

Chemical(s) and type of regulation

PFBS (Notification)

Regulatory information

Regulation and related information

Colorado

Concentration level

700 ppt (stated in the regulation as 700 ng/L)

Chemical(s) and type of regulation

PFHxS (Guidance)

Regulatory information

Translation Level and related information

Concentration level

400,000 ppt (stated in the regulation as 400,000 ng/L)

Chemical(s) and type of regulation

PFBS (Guidance)

Regulatory information

Translation Level and related information

Connecticut

Concentration level

240 ppt

Chemical(s) and type of regulation

PFHxA (Notification)

Regulatory information

Action Level and related information

Concentration level

760 ppt

Chemical(s) and type of regulation

PFBS (Notification)

Regulatory information

Action Level and related information

Concentration level

1,800 ppt

Chemical(s) and type of regulation

PFBA (Notification)

Regulatory information

Action Level and related information

Illinois

Concentration level

140 ppt (stated by the Illinois Environmental Pollution Control Agency as 140 ng/L)

Chemical(s) and type of regulation

PFHxS (Guidance)

Regulatory information

Regulation and related information

Concentration level

2,100 ppt (stated by the Illinois Environmental Pollution Control Agency as 2,100 ng/L)

Chemical(s) and type of regulation

PFBS (Guidance)

Regulatory information

Regulation and related information

Concentration level

3,500 ppt (stated by the Illinois Environmental Pollution Control Agency as 3,500 ng/L)

Chemical(s) and type of regulation

PFHxA (Guidance)

Regulatory information

Regulation and related information

Maryland

Concentration level

140 ppt

Chemical(s) and type of regulation

PFHxS (Guidance)

Regulatory information

Health Advisory

Michigan

Concentration level

370 ppt

Chemical(s) and type of regulation

Gen X or HFPO-DA (MCL)

Regulatory information

Regulation and related information

Concentration level

420 ppt

Chemical(s) and type of regulation

PFBS (MCL)

Regulatory information

Regulation and related information

Concentration level

400,000 ppt

Chemical(s) and type of regulation

PFHxA (MCL)

Regulatory information

Regulation and related information

Minnesota

Concentration level

100 ppt

Chemical(s) and type of regulation

PFBS (Guidance)

Regulatory information

Health Advisory and related information

Concentration level

200 ppt

Chemical(s) and type of regulation

PFHxA (Guidance)

Regulatory information

Health Advisory and related information

Concentration level

7,000 ppt

Chemical(s) and type of regulation

PFBA (Guidance)

Regulatory information

Health Advisory and related information

Nevada

Concentration level

10,000 ppt (stated by the Nevada Division of Environmental Protection as 10 µg/L)

Chemical(s) and type of regulation

PFBS (Guidance)

Regulatory information

Basic Comparison Levels

Related information

Ohio

Concentration level

2,000 ppt

Chemical(s) and type of regulation

PFBS (Guidance)

Regulatory information

Statewide PFAS Action Plan

Concentration level

140,000 ppt

Chemical(s) and type of regulation

PFBS (Guidance)

Regulatory information

Statewide PFAS Action Plan

Washington

Concentration level

345 ppt

Chemical(s) and type of regulation

PFBS (Notification)

Regulatory information

Code and related information

Related information

No state-specific PFAS drinking water regulations*

*as of date of publication

  • Alabama
  • Arizona
  • Arkansas
  • Florida
  • Georgia
  • Idaho
  • Indiana
  • Iowa
  • Kansas
  • Kentucky
  • Louisiana
  • Mississippi
  • Missouri
  • Montana
  • Nebraska
  • North Dakota
  • Oklahoma
  • Oregon
  • South Carolina
  • South Dakota
  • Tennessee
  • Texas
  • Utah
  • Virginia
  • West Virginia
  • Wyoming

Key

Notification

A corporate representative may have to inform an appropriate state official that a drinking water concentration in a water source owned or operated by the corporation (public well, supply tank, etc.) is above the limit. A water supply system also may have to inform its customers if there are any samples that exceed the PFAS values.

Guidance

The state establishes recommended concentration limits for one or more PFAS substances, but no notification or other action is required if concentrations exceed the recommended limits.

MCL

MCLs establish the maximum amount of a PFAS compound that can be present in drinking water. Treatment facilities that supply drinking water must ensure that these limits are met by treating and filtering the drinking water, and also by limiting the discharge of PFAS compounds through permits.

How Do These Limits Impact Businesses?

MCLs set the maximum concentration of a given contaminant that can be present in drinking water. Drinking water systems are ultimately responsible for meeting the applicable MCLs and are required to ensure that drinking water distributed to the public meets these limits. State agencies often include limits for upstream discharges to drinking water sources to ensure that the drinking water provider can comply with the MCLs.

Businesses that currently or historically have used PFAS compounds, or have reason to believe that they may be present in their effluent, should evaluate:

  • Whether their wastewater discharges, either directly or following treatment by the POTW or other treatment facilities, are eventually released to sources that are used for drinking water;
  • Whether their discharge contains any of the PFAS compounds that are regulated in their jurisdiction; and
  • Whether they are likely to be subject to permit conditions limiting the allowable concentration of PFAS compounds in their wastewater discharges.

Acquiring this information will allow businesses to determine whether they need to modify their operations to reduce or eliminate PFAS substances from their waste stream to achieve compliance with an existing standard, or in anticipation of likely future permit conditions.

Conclusion

The regulation of PFAS substances in drinking water will continue to develop over the next year as additional research is conducted on potential health impacts, and as regulators at both the federal and state levels develop a deeper understanding of the prevalence of PFAS compounds in drinking water and the efficacy of different MCLs.

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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