9 PFAS-Related Items on the OMB’s Unified Agenda

As the Pace® Program Manager for Environmental Compliance, I am often asked what PFAS regulatory actions our clients can expect from U.S. EPA. The Spring 2025 Unified Agenda released by the U.S. Office of Management and Budget (OMB) is a good place to begin to answer this question. As expected, several of the agenda items in the latest publication pertain to PFAS, creating a kind of “checklist” for actions to watch and be ready for in the weeks and months ahead.  

What is the Unified Agenda? 

If you’re not familiar with the Unified Agenda of Federal Regulatory and Deregulatory Actions, commonly referred to as the Unified Agenda, it is a government-wide publication that provides uniform reporting of regulatory activities under development throughout the federal government. The Unified Agenda is published twice a year, typically in the spring and fall, by the Office of Information and Regulatory Affairs (OIRA), which sits within the OMB. The most current Unified Agenda publications are dated Spring 2025, however were only recently released. 

The Unified Agenda is comprised of several Agency Rule Lists submitted by individual agencies. Because PFAS is largely the domain of the EPA, we can focus our efforts there. For the record, the Department of Defense (DOD) and the Government Services Administration (GSA) both have actions related to restricting the procurement of items containing PFAS. The DOD’s action is in the proposed rule stage and the GSA’s rule has been withdrawn. 

PFAS Features Prominently in Unified Agenda 

The EPA’s Agency Rule List contains nine items pertaining to PFAS. I’ll summarize them here, provide links, and offer perspectives where appropriate.  

• ELGs for OCPSF Industry – This one should come as no surprise to anyone as the EPA included effluent guidelines for businesses in the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) industry in Preliminary Plan 16. While the OCPSF industry includes several subcategories, as published, the proposed rule specifically calls out “formulators” of PFAS. The Notice of Proposed Rulemaking (NPRM) is scheduled to be published in January of 2026. 

• PFAS Requirements in National Pollutant Discharge Elimination System (NPDES) Permit Applications – This action is significant as it will cover a wide range of potential emitters of wastewater discharge containing PFAS. Any entity permitted directly by the U.S. EPA will be covered. Since state permitting authorities typically follow the U.S. EPA’s requirements, it’s expected that those permitted at the state level will be covered as well.  

This item is also in the Proposed Rule Stage with the NPRM scheduled to be released in November of 2025. We will be eagerly waiting to see the details. For example, which PFAS will be included, and at what concentrations?  The EPA may also elect to include criteria for other matrices covered by NPDES, including biosolids and stormwater runoff. The final rule is scheduled for May of 2027. 

• Extending the Deadline for NPDWR Compliance – Earlier this year, the EPA announced that it intended to extend the deadline for public water systems to meet PFAS Maximum Contaminant Levels (MCLs) set by the National Primary Drinking Water Regulations (NPDWR). The NPRM is still expected in October of 2025, with the final rule scheduled to be released in April of 2026. In its announcement, the agency said they anticipate extending the deadline to 2031, but a date is not specifically mentioned, and the proposed rule has yet to be published in the Congressional Federal record.  

• Withdrawal of PFAS from NPDWR – In the same release in which the EPA announced its plans to extend the NPDWR compliance deadline, it also announced plans to withdraw the limits on PFHxS, PFNA, and HFPO-DA (GenX) as well as the Hazard Index limits for these three PFAS plus PFBS set under the Safe Drinking Water Act. The NPRM is expected this month (September 2025), with the final rule scheduled to be released in February of 2026. Note that until this rule is finalized, the regulations enacted in 2024 are still in effect. 

• Designation of 9 PFAS as Hazardous Constituents Under RCRA – This proposed rule has been sitting in limbo since early 2024, but the wait to see what the EPA will do could soon be over as the final rule is expected to be published in April of 2026. If finalized as proposed, this designation is likely to have a significant impact on the U.S. solid waste industry.  

• TSCA PFAS Reporting Exemptions and Scope Changes – The Toxic Substances Control Act (TSCA) warranted a couple of entries in the Unified Agenda. As it currently stands, manufacturers and importers are required to report PFAS usage and production from 2011 to 2022. The EPA plans to propose exemptions and other changes to the scope of the rule based on feedback from industry. The NPRM is scheduled for December of 2025, with finalization by June of 2026. 

• Changes to TSCA Reporting Deadlines – The EPA has also proposed changing the data submission period for the PFAS reporting rule. Under the interim final rule, 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.  This interim rule became effective on May 13, 2025, although comments were still accepted through June 2025. 

• Addition of PFAS to TRI – Way back in October of 2024, the EPA proposed an action that would add nearly 100 PFAS compounds to the Toxic Release Inventory (TRI) – 16 individual PFAS and 15 categories of PFAS. The final rule is scheduled to be published in February of 2026. 

• Changes to Supplier Notification Rules for PFAS Automatically Added to TRI – Lastly, as outlined under the National Defense Authorization Act (NDAA), PFAS compounds are automatically added to TRI if they meet certain criteria. This change would require covered suppliers to notify their customers of products containing TRI-listed chemicals added by the NDAA. The NPRM was published in January, and the final rule is expected in November of 2025. 

The PFAS Regulatory Timeline 

I’ve taken the regulatory actions above and put them into a timeline. While these things don’t always follow the published timeline, viewing the schedule this way may help you focus your readiness efforts.  

May 13, 2025 – TSCA reporting deadline extension (already in effect). 

September 2025 – Withdrawal of PFAS from NPDWR. NPRM to be issued for public comment. 

October 2025 – NPDWR compliance deadline extension. NPRM to be issued for public comment. 

November 2025 – Changes to TRI supplier notification. Final rule scheduled for publication. 

November 2025 – Addition of PFAS to NPDES permitting. NPRM to be issued for public comment.  

December 2025 – TSCA reporting exemptions and scope change. NPRM to be issued for public comment. 

January 2026 – ELGs for OCPSF industry. NPRM to be issued for public comment. 

February 2026 – Addition of PFAS to TRI. Final rule scheduled for publication. 

February 2026 – Withdrawal of PFAS from NPDWR. Final rule scheduled for publication.  

April 2026 – NPDWR compliance deadline extension. Final rule scheduled for publication. 

June 2026 – TSCA reporting exemptions and scope change. Final rule scheduled for publication. 

May 2027 – Addition of PFAS to NPDES permitting. Final rule scheduled for publication. 

PFAS Clean Up at the EPA 

Most of the PFAS-related regulatory activities included in the Spring 2025 Unified Agenda were first announced months ago. For the most part, this list contains a lot of loose ends that need to be cleaned up for the sanity of compliance professionals nationwide. We’ll be watching closely as these proposals get firmed up, finalized, and published.  

The elephant in the room is whether the current EPA administration will extend their focus on PFAS with future regulatory actions not included in the Spring 2025 Unified Agenda. There is little doubt in my mind that they will, although it’s not certain that they will be as aggressive as the last administration or their timelines. Obviously, a number of timelines in place before the current administration took office were predictably extended. Even so, there is a good chance Congress will pick up some of the slack, so we will be watching any emerging regulatory actions from that sector as well. Numerous states continue to develop their own legislation, and regulations separate and apart from what’s taking place at the federal level. 

As always, you can count on us to bring you our perspectives and any technical information we think might be helpful in your quest to remain compliant with the latest rules and regulations. If you have questions, don’t hesitate to reach out to us. You can also request a quote for PFAS services, and our sales team will work with me and others to get you the information you need.