On September 4, 2025, the Office of Management and Budget (OMB) published the Trump Administration’s Spring 2025 Unified Agenda. The U.S. Environmental Protection Agency’s (EPA) Unified Agenda includes the following rulemakings regarding per- and polyfluoroalkyl substances (PFAS):

• PFAS Requirements in National Pollutant Discharge Elimination System (NPDES) Permit Applications: EPA notes that the list of pollutants in the NPDES application regulations has not been updated since 1987 and currently does not include PFAS. According to EPA, this proposed rulemaking seeks to update requirements for several of the existing NPDES permit applications to address monitoring and reporting of PFAS. EPA intends to issue a notice of proposed rulemaking (NPRM) in November 2025 and a final rule in May 2027.
• Extending the Compliance Deadline for the PFAS National Primary Drinking Water Regulation (NPDWR) Rulemaking: EPA states that it will propose a new rule that provides additional time for public water systems to meet the compliance deadlines for the Maximum Contaminant Levels (MCL) in the NPDWR for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS). EPA states that through this rule, it “intends [to] address the most significant compliance challenges EPA has heard from public water systems and other stakeholders while still ensuring the long-term protection of the American people from PFAS-contaminated drinking water.” EPA intends to issue an NPRM in October 2025 and a final rule in April 2026. More information on EPA’s PFAS NPDWR is available in our May 9, 2024, memorandum.
• Withdrawal of Regulatory Determinations and removal of Related Provisions for Four PFAS Substances (Perfluorohexane Sulfonic Acid (PFHxS), Perfluorononanoic Acid (PFNA), Hexafluoropropylene Oxide Dimer Acid And Its Ammonium Salt (HFPO-DA, Commonly Known as GenX), and the Mixture of These Three PFAS Plus Perfluorobutane Sulfonic Acid (PFBS)): EPA intends to propose to withdraw its regulatory determinations to regulate PFHxS, PFNA, HFPO-DA, and the mixture of these three PFAS plus PFBS under the Safe Drinking Water Act (SDWA). EPA also intends to propose to rescind all associated regulatory provisions associated with the final PFAS NPDWR exclusive to these PFAS that were promulgated pursuant to the regulatory determinations that EPA is now proposing to withdraw. EPA intends to issue an NPRM in September 2025 and a final rule in February 2026.
• Listing of Specific PFAS as Hazardous Constituents: On February 8, 2024, EPA published a proposed rule to add nine specific PFAS, their salts, and their structural isomers, to its list of hazardous constituents in 40 C.F.R. Part 261 Appendix VIII. If issued in final, when corrective action requirements are imposed at a Resource Conservation and Recovery Act (RCRA) treatment, storage, and disposal facility, these PFAS would be among the hazardous constituents expressly identified for consideration in assessments and, when necessary, further investigation and cleanup of these facilities. EPA states that it is considering public comments as it develops a final rule. EPA intends to issue a final rule in April 2026. More information on EPA’s proposed rule is available in our February 5, 2024, memorandum.
• PFAS Data Reporting and Recordkeeping under the Toxic Substances Control Act (TSCA); Revision to Regulation: EPA states that it is considering a proposed rule to amend the TSCA regulation for reporting and recordkeeping requirements for PFAS. As promulgated in October 2023, the regulation requires manufacturers (including importers) of PFAS in any year between 2011-2022 to report certain data to EPA related to exposure and environmental and health effects. According to the Unified Agenda item, EPA plans to propose the incorporation of certain exemptions and other modifications to the scope of the reporting rule. EPA intends to issue an NPRM in December 2025 and a final rule in June 2026. More information on EPA’s October 2023 final rule is available in our October 3, 2023, memorandum.
• PFAS Data Reporting and Recordkeeping under TSCA; Change of Submission Period: EPA states that it is amending the data submission period for the TSCA PFAS reporting rule by changing the start date for submissions and making corresponding changes to the end dates for the submission period, i.e., the data submission period begins on April 13, 2026, and ends on October 13, 2026, with an alternate end date for small manufacturers reporting exclusively as article importers of April 13, 2027. As reported in our May 12, 2025, memorandum, EPA issued an interim final rule amending the regulation on May 13, 2025. 90 Fed. Reg. 20236.
• Addition of Certain PFAS to the Toxics Release Inventory (TRI): EPA states that it is developing a final action to add individually listed PFAS and PFAS categories to the TRI list of toxic chemicals subject to reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA) and the Pollution Prevention Act (PPA). EPA is evaluating comments received on the proposed rule published on October 4, 2024, and will consider how to address PFAS compound categories and what events may trigger the automatic addition of a PFAS to the TRI. EPA intends to issue a final rule in February 2026. More information on EPA’s proposed rule is available in our October 17, 2024, memorandum.
• TRI; Clarification to Supplier Notification Provision Due to Automatic Additions of PFAS under the National Defense Authorization Act for Fiscal Year 2020 (NDAA): The NDAA adds certain PFAS automatically to the TRI beginning January 1 of the year following specific triggering events. EPA states that it is making conforming edits to the TRI regulation to include explicitly PFAS that are added to the TRI chemical list automatically pursuant to the NDAA in the regulation’s definition of toxic chemical. According to EPA, this edit confirms that the TRI supplier notification provision “requires covered suppliers to notify customers receiving a mixture or other trade name product containing a TRI-listed chemical with the first shipment of each calendar year, with such a requirement beginning on January 1 of the applicable year; thus, supplier notifications are required as of January 1 for any NDAA-added PFAS.” EPA intends to issue a final rule in November 2025. More information on EPA’s proposed rule is available in our January 22, 2025, blog item.

EPA’s list of long-term actions includes:

• Revisions to the Metal Finishing Effluent Guidelines to Address PFAS Discharges in Chromium Electroplating Wastewater: EPA is revising the Metal Finishing Effluent Limitation Guidelines at 40 C.F.R. Part 433 to address discharges of PFAS in wastewater from chromium electroplating facilities. EPA intends to issue an NPRM in July 2026.
• Addressing PFAS in the Environment: On April 12, 2023, EPA issued an advanced notice of proposed rulemaking (ANPRM) seeking comment on potential future designations of PFAS under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The comment period closed June 12, 2023. EPA subsequently issued a 60-day extension for public comment to August 11, 2023. EPA states that it is now reviewing and evaluating comments. EPA has not determined when it will issue an NPRM. More information on the ANPRM is available in our April 13, 2023, memorandum.