As 2025 draws to a close, new federal and state PFAS rules are reshaping reporting, drinking water standards, and product restrictions across the U.S. This month’s summary includes proposed changes to TSCA reporting and noteworthy PFAS regulatory developments in Washington, Wisconsin, California, and Georgia.
FEDERAL PFAS ACTIONS
U.S. EPA Proposes Update to Definition of WOTUS
On November 20, 2025, the EPA and the U.S. Army Corps of Engineers published a proposed rule to update the definition of “waters of the United States” (WOTUS) under the Clean Water Act. Key changes include removing “interstate waters” from the WOTUS definition and expanding the list of exclusions, such as adding certain ditches and groundwater, to reflect a narrower regulatory approach. .png?width=350&height=350&name=blog%20square%20(20).png)
The redefinition reduces federal jurisdiction over navigable waters and increases responsibility at the state and local level. The primary program impacted is likely to be the National Pollutant Discharge Elimination System (NPDES), which is already administered at the state level in all but three states. Consequently, these changes may prompt states to revisit their wastewater discharge permitting program to ensure waters that fall outside the revised definition of WOTUS remain protected. Businesses managing PFAS should closely track both federal and state definitions to ensure full compliance as jurisdictional boundaries continue to evolve.
TSCA Reporting Changes
The 2023 TSCA rule requiring companies to report PFAS uses, production volumes, disposal, exposures, and hazards dating back to January 1, 2011, drew significant industry criticism for being overly burdensome. In response, the U.S. EPA announced it would take action to lower the reporting burden for PFAS, including adding exemptions for:
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PFAS in mixtures or articles at concentrations of 0.1% or lower
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PFAS imported as part of a product
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PFAS manufactured or used for R&D purposes
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PFAS classified as byproducts or impurities
The proposed rule also shortens the reporting window from six months to three months, beginning 60 days after the final rule takes effect. The inception date for historical remains January 1, 2011, under this proposal.
KEY STATE ACTIONS
Wisconsin
Approximately one-third of Wisconsin residents rely on private wells for drinking water. Assembly Bill 635 aims to improve public disclosure and response to groundwater contamination. The bill requires the Department of Natural Resources (DNR) to notify county and tribal health departments within seven business days when groundwater standards for PFAS, lead, and nitrates are exceeded.
While the Wisconsin Department of Health Services has developed groundwater standards, as of late 2025, final enforceable PFAS groundwater standards have not yet been promulgated by the Wisconsin DNR. Entities that manufacture, use, or dispose of PFAS in ways that could affect groundwater should monitor these developments closely, as future rulemaking may expand their compliance obligations.
The Wisconsin Department of Natural Resources also announced the launch of Be Well Informed. This new online tool was developed in partnership with the University of Wisconsin and is designed to help private well owners interpret their certified drinking water lab test results.
Washington
On November 20, 2025, Washington state adopted Cycle 1.5. This rule updates Washington’s broader “Safer Products for Washington” program that targets intentionally added PFAS in consumer products. Under Cycle 1.5, the Department of Ecology amended Chapter 173337 WAC to prohibit the manufacture, sale, and distribution of products in three categories:
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apparel and accessories
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automotive washes
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cleaning products
The rule also requires manufacturers to report intentionally added PFAS in several additional categories:
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certain outerwear and “extreme and extended use” apparel
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footwear
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recreational and travel gear
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cookware and kitchen supplies
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car and floor waxes
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hard-surface sealers
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ski waxes
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firefighting personal protective equipment
Washington uses a "rebuttable presumption" approach: if total fluorine exceeds 50 parts per million (ppm) in regulated products, the Department of Ecology presumes intentionally added PFAS. Manufacturers can rebut this finding with supply chain documentation, safety data sheets, and expert analysis. Restrictions begin on January 1, 2027, and the first reports are due January 31, 2027.
Watch: Quantifying PFAS in Consumer and Related Products
Minnesota
On December 8, 2025, the Minnesota Pollution Control Agency (MPCA) finalized administrative rules requiring manufacturers to report PFAS in products sold in the state. The rules provide flexibility through options such as group reporting, reporting concentration ranges instead of exact amounts, and processes for waivers, extensions, and trade secret protections. They also establish a one‑time $800 fee to support implementation. The MPCA is rolling out the PFAS Reporting Information System for Manufacturers (PRISM), with a soft launch to selected manufacturers in December 2025 and full access beginning in January 2026. Initial reports under the new administrative rules are due July 1, 2026.
Illinois
In November, the Illinois EPA issued a health advisory of 700 ppt for 6:2 FTS. While health advisories in Illinois serve as informal guidance and are not enforceable drinking water standards, they inform state rulemaking proposals under 35 Ill. Adm. Code 620.601. Illinois currently has established groundwater standards for six PFAS compounds (PFOA, PFOS, PFNA, PFBS, PFHxS, and HFPO-DA/GenX) in Class I (potable) groundwater. However, no additional PFAS drinking water MCLs beyond federal limits have been set.
Georgia
In early November, the Georgia Environmental Protection Division proposed updating the state’s Rules for Safe Drinking Water to align PFOA and PFOS limits with federal standards. A statewide stakeholder meeting is set to be held on December 10th.
California
On October 29, the California State Water Resources Board issued new and revised notification and response levels for several PFAS. Key changes include:
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Notification levels for PFOA and PFOS were revised to 4 ppt to align with the current National Primary Drinking Water Regulations.
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The response level for PFHxS was set to a running annual average (RAA) of 10 ppt.
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PFHxA now has a response level of 1,000 ppt and a notification level of 10,000 ppt as measured by the RAA.
OF INTEREST
EPA Fact Checks Claims That It Approved PFAS in Pesticides
EPA Poised to Approve Incineration as PFAS Destruction Method in Upcoming Guidance
Congress Considers PFAS Liability Protections for Construction and Water Industries
Testing Food for PFAS and Assessing Dietary Exposure | FDA
PFAS in Firefighting Foam (AFFF) and Equipment: State-by-State Regulations
Pharma Pushes Back on State PFAS Regulations
Toxic Sewage Sludge Case Now on Appeal
Leachate Recirculation to Reduce PFAS Discharge from Landfills
PEER Files IQA Request to Correct EPA Claim That PFOA Has Been Phased Out
PFAS WEBINARS
Webinar: Comprehensive Overview of Core Discrete Fracture Network (COREDFN): A High-Resolution Approach to Bedrock Investigations Involving VOCs and PFAS – Part 2 of this webinar will be conducted on December 10 at noon ET and focus on COREDFN adaptation for sites with potential PFAS contamination. This session is particularly suited to professionals conducting Environmental Site Assessments, CERCLA compliance reviews, and remediation projects. Register here.
LOOKING AHEAD TO 2026
As PFAS regulatory requirements accelerate and compliance obligations grow more complex, Pace® is here to support you with testing expertise, regulatory insight, and custom project solutions. If you have questions about compliance, want to learn more about PFAS testing, or need a project-specific quote, contact our PFAS specialists today. We look forward to helping you navigate these developments and stay ahead of the curve in 2026 and beyond.
