EPA Announces List of Actions to Combat PFAS Contamination

On April 28, 2025, the EPA finally announced its strategy to address PFAS. The list of actions announced by the EPA is as follows:  

Strengthening the Science  

• Designate PFAS agency lead to align and manage PFAS efforts across programs. 
• Implement PFAS testing strategy under Toxic Substances Control Act ("TSCA") Section 4.
• Launch efforts on air-related PFAS information collection and measurement techniques.
• Address information gaps where not all PFAS can be measured and controlled.
• Annually update the PFAS Destruction and Disposal Guidance as EPA assesses the effectiveness of available treatment technologies.
• Develop testing methods to improve detection and strategies. 

Fulfilling Statutory Obligations and Enhancing Communication 

• Develop effluent limitation guidelines ("ELGs") for PFAS manufacturers and metal finishers and evaluate other ELGs.
• Address the most significant compliance challenges and requests from Congress and drinking water systems related to national primary drinking water regulations for certain PFAS.
• Determine how to use the Resource Conservation and Recovery Act to address releases from manufacturing operations of producers and users of PFAS.
• Add PFAS to the Toxic Release Inventory in line with the 2020 National Defense Authorization Act.
• Enforce Clean Water Act and TSCA limitations on PFAS use.
• Use Safe Drinking Water Act authority to investigate and address immediate endangerment.
• Prioritize risk-based review of new and existing PFAS chemicals.
• Implement TSCA section 8(a)7 to collect information consistent with the TSCA, without overburdening small businesses and article importers.  
• Work with Congress and industry to establish a clear polluter-pays liability framework that protects passive receivers.   

Building Partnerships 

• Advance remediation and cleanup efforts where drinking water supplies are impacted by PFAS contamination.
• Work with states to assess risks from PFAS contamination and develop analytical and risk assessment tools.
• Finish public comment period for biosolids risk assessment and determine path forward based on comments.
• Provide assistance to states and tribes on enforcement efforts.
• Review and evaluate any pending state air petitions.
• Support investigations into violations to hold polluters accountable. 

With these actions, the EPA intends to address PFAS from all EPA program offices and suggests that these are the first of many actions the EPA will take to address PFAS during the Trump administration. Although it is too early to tell how these items will be implemented and may in fact differ from actions already in place, entities that may be impacted by these regulatory programs should monitor EPA, congressional, and state action on PFAS moving forward.