“Forever Chemicals”: The Shifting Landscape of PFAS Regulation

by Brookelynn Stone, Associate Member, University of Cincinnati Law Review Vol. 94

I. Introduction

Per- and polyfluoroalkyl substances (“PFAS”) have gained tremendous attention in the last two decades, largely due to growing health concerns over their impact on public health and the environment.¹ PFAS are a large group of synthetic chemicals used in consumer products and industrial processes.² Due to their chemical composition, PFAS are highly persistent in the environment, gaining the name “forever chemicals.”³ As a result, nearly all people in the United States have been exposed to PFAS and have traces of it in their blood.⁴

In response to PFAS’ growing health risks, Congress and the Environmental Protection Agency (“EPA”) have taken steps to thwart the impact of these forever chemicals by establishing national drinking water standards under the Safe Drinking Water Act (“SDWA”) and the Toxic Substances Control Act (“TSCA”), part of EPA’s 2021 PFAS Strategic Roadmap.⁵ However, there has been recent movement to rescind and reconsider the limits on PFAS in drinking water as well as weaken the reporting requirements for importers and manufacturers.⁶ Despite the uncertainty with federal PFAS action, states are continuing to enact their own reporting obligations, product restrictions, and drinking water standards.⁷

This article examines the evolving regulatory landscape governing PFAS in the United States, focusing on both federal and state level regulations. It highlights how the cost of compliance has become a central feature of the PFAS debate and how shifting federal priorities have contributed to uncertainty that affects both regulated entities and communities. Part II provides historical background on the development and use of PFAS, including its introduction into consumer products, firefighting foams, and outlines the introduction of the SDWA. Part II also addresses the influx of state level PFAS legislative efforts. Part III discusses the public health implications of regulatory instability, highlighting the relationship between compliance costs and environmental justice. Part IV concludes by reiterating the importance of PFAS regulation, especially in the form of stable, coordinated regulation.

II. Background

A. Development and Use of PFAS

PFAS are a family of thousands of synthetic chemicals first used in nuclear weapons development by the Manhattan Project during World War II.⁸ In the decades that followed, the use of PFAS expanded significantly due to their unique chemical properties, making their way into consumer products.⁹ PFAS have been used in a wide range of consumer, commercial, and industrial products primarily because products containing PFAS can withstand heat and repel water and stains.¹⁰ These properties make PFAS popular in products such as “non-stick” cookware, clothing, leather, carpets, food packaging, firefighting foam, and pesticides.¹¹ PFAS have also been used in certain medications, contact lenses, IV tubing, and more.¹² Individuals can be exposed to PFAS through air, soil, food or water, though water is thought to be the most common source of exposure.¹³

The primary concern surrounding PFAS stems from their persistence in the environment and inability to be broken down through traditional processes, hence the name “forever chemicals.”¹⁴ And when disposed of or buried, they seep into the soil and groundwater, creating lasting generational health risks.¹⁵ The EPA has acknowledged that “there is evidence that exposure to PFAS can lead to adverse health outcomes in humans,”¹⁶ such as kidney and testicular cancer, liver and kidney damage, and harm to nervous and reproductive systems,¹⁷ even if only exposed to a minimal amount.¹⁸

As awareness of these health risks increase, so too has litigation related to PFAS exposure. One current example involves aqueous film-forming foam (“AFFF”), a PFAS-based firefighting foam used extensively by firefighters and military personnel for decades.¹⁹ For years, firefighters and military personnel used AFFF in training and emergency responses, yet were unaware of the potential health consequences.²⁰ As a result, nearly 20,000 total cases have been consolidated in a multi-district litigation, alleging that prolonged exposure to AFFF caused serious illnesses, such as cancer.²¹ This ongoing litigation highlights the widespread nature of PFAS exposure and the historical lack of regulatory oversight governing its use.

Recent scientific evidence and widespread litigation has forced regulators to consider the long-term impact PFAS use causes. Notably, the Biden Administration issued the first-ever national legally enforceable drinking water standards for six PFAS compounds, as explored in the following section.²²

B. Federal PFAS Initiatives

Enacted in 1974, the SDWA aims to protect the nation’s public drinking water supply.²³ This law “authorizes the United States EPA to set national-health-based standards for drinking water to protect against both naturally-occurring and man-made contaminants that may be found in drinking water,”²⁴ taking into consideration the available technology and associated costs.²⁵ Since its inception, there has been significant progress regarding the requirements, minimum standards, and monitoring of water sources.²⁶

During the Biden administration, the EPA utilized the SDWA to implement more restrictive regulations for PFAS in drinking water, and on April 10, 2024, the EPA announced its final National Primary Drinking Water Regulation (“NPDWR”) for six PFAS.²⁷ The EPA stated that it “expects that over many years the final rule will prevent PFAS exposure in drinking water for approximately 100 million people, prevent thousands of deaths, and reduce tens of thousands of serious PFAS-attributable illnesses.”²⁸ In addition, unprecedented amounts of funding were made available to assist in the implementation of PFAS treatment measures as well as nearly $1 billion in funding through the Investing in America agenda to help states with initial PFAS testing and treatments.²⁹

The final rule has three main requirements. First, public water systems must monitor for the six PFAS, complete the initial monitoring in three years, and undergo ongoing compliance monitoring.³⁰ The public must also be informed of the levels of PFAS in their drinking water beginning in 2027.³¹ Second, public water systems have five years (i.e., 2029) to implement solutions to their water supplies if the water levels exceed the Maximum Contaminant Levels (“MCLs”).³² Lastly, in five years (i.e., 2029), public water systems that have PFAS in drinking water in violation of this rule must take action to cure it and provide the public with notification of its violation.³³ Because the SDWA controls all public water utilities, setting limits on PFAS in drinking water may drastically reduce contamination in water consumed and lead to improvements in human health.³⁴

Following a change in administration, in May of 2025 the EPA announced that it will delay the compliance deadlines for two PFAS chemicals, PFOS and PFOA, until 2031.³⁵ Additionally, the EPA announced its plan to rescind the regulations and reexamine the regulatory determinations for four PFAS chemicals.³⁶ Moreover, the EPA is attempting to utilize ongoing litigation as the vehicle to eliminate the Index PFAS MCLs, siding with a group of petitioners that are challenging the NPDWR.³⁷ Importantly, the SDWA has an anti-backsliding provision that prohibits the EPA from weakening drinking water standards once one has been set.³⁸ Essentially, the EPA is asking the court to do what itself is not allowed to do.³⁹

Despite this ongoing effort to rescind and delay PFAS regulations, EPA Administrator Zeldin stated, “We are on a path to uphold the agency’s nationwide standards to protect Americans from PFO and PFOS in their water . . . [and] we will work to provide common-sense flexibility in the form of additional time for compliance.”⁴⁰ The EPA’s announcement and its actions so far have been met with both appreciation and criticism. The stringent compliance standards and the timeline in the final NPDWR would prove difficult for small and rural communities.⁴¹ Conversely, environmentalists believe human health is being “delayed and undermined by EPA Administrator Zeldin’s current plans.”⁴²

Although the final NPDWR represents a significant effort by the previous Biden Administration to mitigate exposure to PFAS and reduce the associated health effects, its scope is limited to drinking water systems. Moreover, the shifting compliance timelines and attempts to rescind demonstrate the regulatory uncertainty surrounding this issue.

C. Toxic Substances Control Act

In addition to the drinking water regulation, the EPA has issued a final rule for reporting and recordkeeping requirements for PFAS under the Toxic Substances Control Act (“TSCA”).⁴³ In 2023, the EPA finalized a rule requiring persons that manufacture or import products containing PFAS to submit information about PFAS uses, production volumes, exposures, disposal, and hazards to the EPA dating back to January 1, 2011.⁴⁴ The reporting requirements are intended to improve regulatory oversight and inform future risk management decisions.⁴⁵ However, the EPA has recently proposed changes that would provide exemptions for specified imported goods containing PFAS.⁴⁶ EPA Administrator Lee Zeldin stated, “[The] proposal is grounded in commonsense and the law, allowing us to collect the information we need to help combat PFAS contamination without placing ridiculous requirements on manufacturers.”⁴⁷ While this may reduce the regulatory burden that the final rule imposes on manufacturers, it risks limiting the availability of data necessary to understand and prevent PFAS contamination at its source.

D. State-level Legislation and Regulation

Federal legislation and regulations establish a regulatory floor that states are required to meet, but states may choose to implement more stringent standards.⁴⁸ In 2025 alone, over 350 PFAS-related bills were introduced across 39 states, and legislation was enacted in five states.⁴⁹ States show significant interest in PFAS legislation and protecting their communities, whereas the federal government remains in flux. The proposed legislation largely aims to require reporting obligations for products containing PFAS such as consumer products, firefighting foam, emission controls, and even water quality standards.⁵⁰

Notably, Minnesota PFAS legislation, Minn. Stat. §116.943, known as “Amara’s Law,” requires mandatory reporting obligations to the Minnesota Pollution Control Agency (“MPCA”) and includes phased prohibitions on the sale of specified products that contain PFAS.⁵¹ These products—carpets, cookware, cosmetics, and more—will be prohibited from sale and starting in 2032, there will be a general ban on all products containing PFAS unless the use is found “currently unavoidable.”⁵² This rule will have significant effects on companies in Minnesota and companies whose products make their way into the stream of commerce there.

As for state level drinking water regulations, at least twenty states currently have regulatory standards for at least one PFAS chemical in drinking water, along with a handful of states that are introducing legislation to establish MCLs or update them.⁵³ However, this leaves around twenty-five states that do not have state-specific PFAS drinking water regulations.⁵⁴ Because regulation of drinking water varies so drastically by state, this leaves a patchwork of regulations and standards and a lack of consistency. These state-level efforts reflect a proactive approach to mitigating PFAS exposure, but they also raise questions about consistency, enforcement, and equitable distribution of public health protections.

III. Discussion

Federal efforts to monitor and regulate PFAS highlights the growing concern over the health effects associated with PFAS exposure. Compliance costs and implementation burdens continue to shape the debate and federal reporting frameworks do not fully restrict ongoing PFAS use.⁵⁵ At the same time, states have increasingly adopted their own regulations, creating uneven protections across jurisdictions. This section examines how the overlapping federal and state efforts contribute to both progress and fragmentation.

A. Federal Regulatory Instability and Shifting Costs

Delaying or weakening PFAS regulation does not eliminate the economic burden of contamination. Rather, it shifts those costs to individuals and communities exposed to contamination. Although the EPA’s final NPDWR and TSCA PFAS Data Reporting Rule represent significant advancements in PFAS regulation, recent actions surrounding them illustrate the broader instability of the federal approach.

Compliance with the NPDWR requires public water systems to monitor for specified PFAS compounds and install advanced treatment technologies if the contamination exceeds allowed levels.⁵⁶ These systems require a substantial amount of capital upfront as well as both ongoing and remedial costs.⁵⁷ The EPA announced compliance with the NPDWR will cost about $1.5 billion annually, though some industry analysts estimate that number to be closer to $3.8 billion.⁵⁸ Regardless of the precise cost, these estimates demonstrate the financial burden placed on water systems and the communities in the area.

These projected compliance costs, however, only represent one side of the argument. NYU Langone researchers conducted a study on roughly 5,000 Americans, identifying thirteen medical conditions that may arise due to PFAS exposure, such as infertility, diabetes, and endometriosis.⁵⁹ When discussing the medical costs associated with these conditions and reduced worker productivity across a lifetime, these are real costs that are borne by the economy and communities. The study estimates the resulting economic burden to be, at a minimum, $5.5 billion, and up to $63 billion annually.⁶⁰ PFAS studies are ongoing, and importantly, studies specifically involving the long-term effects of this exposure are sparse.⁶¹ A senior author at NYU Langone stated, “Based on our estimates, the cost of eradicating contamination and replacing this class of chemical with safer alternatives is ultimately justified when considering the tremendous economic and medical risks of allowing them to persist in the environment.”⁶²

Framing remedial measures and compliance obligations as a deterrent to regulation fundamentally misunderstands the magnitude of risk public health faces and muddies the fact that individuals’ health is a far greater cost at risk through continued exposure. Again, nearly all Americans have traces of PFAS in their blood.⁶³ Continued exposure may result in increased medical costs, reduced quality of life, and long-term public health consequences that are far more difficult to remedy. Although the EPA has cited the need for “common sense flexibility,” these measures undermine predictability and weaken the preventative function of public health regulation. Public health protections should not fluctuate with administrative priorities, particularly where there is serious risk of exposure and documentation of these chemicals lasting, irreversible impact.

B. State Action and the Patchwork Issue

As mentioned, states have increasingly taken matters into their own hands and some have adopted stringent PFAS regulations, aiming to regulate PFAS at the source.⁶⁴ These efforts reflect a rational response to regulatory gaps, while also demonstrating the limitations of existing federal accountability mechanisms.

Recent litigation, such as the ongoing AFFF MDL, has played an important role in bringing attention to the harms caused by PFAS.⁶⁵ Yet this stresses the limitations of tort-based accountability, as it is a reactive remedy. While individuals may end up being compensated, their concerns are addressed only after the harm has been done. Litigation is also a slow, costly, and burdensome route to justice, and it cannot evenly reach all affected populations. As a result, relying on litigation alone is insufficient and only delays accountability.

Likewise, regulatory accountability mechanisms have fallen short as they fail to operate at the source of contamination. Under TSCA Section 8(a)(7), reporting and record keeping requirements do not, by themselves, restrict production, distribution, or environmental release.⁶⁶ Rather, they are a tool to ensure the EPA receives reports and records to ensure transparency and provide light on PFAS use in commerce. Further, the proposed exemptions for certain imported goods would weaken these reporting requirements and effectively undermine the EPA’s ability to track PFAS throughout global supply chains.⁶⁷ Absent stronger regulatory controls at the source, manufacturers may continue to use PFAS, placing communities at risk.

Conversely, Minnesota’s sweeping PFAS regulation illustrates how states can pursue more preventative regulation. By combining mandatory reporting requirements and phased prohibitions on products, Minnesota can target PFAS at its source rather than relying on remediation after exposure.⁶⁸ This approach places compliance obligations on manufacturers and distributers, rather than relying primarily on downstream remediation. Other states, such as Maine, have introduced similar regulations, further reinforcing the effectiveness of source control as a strategy to reduce PFAS exposure.⁶⁹

However, the variety of state-level regulations has produced a fragmented regulatory landscape. Not all states are akin to Minnesota and Maine’s PFAS regulations, and regulated entities operating in various states are faced with differing compliance requirements and timelines. This patchwork system increases complexity and creates uneven health protections for communities. State action is proving to be valuable, but it underscores the need for a more stable and coordinated federal framework.

C. Potential Priorities for the Next Administration

Under the previous Biden-Administration, significant strides were made in implementing the government-wide plan to battle PFAS pollution. While the current EPA has apparently made addressing PFAS a top priority as well, the full extent of their progress will only be measurable once the term has concluded.⁷⁰ However, because the contamination crisis is hardly over, the next administration should consider the following priority actions: provide the EPA with ample funding for PFAS, protect drinking water from additional PFAS, and require stringent compliance standards for manufacturers of products containing PFAS and implement phased prohibitions on the use of PFAS.⁷¹

First, if the EPA is well funded and staffed this could aid in their efforts to conduct research and reviews of PFAS, and in turn help support the current and future efforts to combat PFAS contamination. Second, the NPDWR currently only protects against six PFAS, but the EPA is collecting monitoring data for 29 unregulated PFAS in drinking water from 2023 to 2026, and early results suggests that many unregulated PFAS have been detected in the drinking water available to communities.⁷² The agency should prioritize clean drinking water and issue standards to limit the levels of additional PFAS in water. Lastly, requiring strict compliance standards coupled with phased prohibitions on products containing PFAS could help with the overall pollution and act as source control management. This could mirror state regulations such as Minnesota. This would provide “source control” and replace the current patchwork of state laws and possibly provide regulated entities with more consistency with compliance standards.

IV. Conclusion

PFAS contamination presents a persistent, far-reaching threat to public health and the environment, one that cannot be addressed through delayed compliance, exemptions, or a fragmented approach. Although recent federal efforts reflect the importance of addressing PFAS, it is being undermined by the current EPA’s actions. The EPA has and can mitigate PFAS contamination, but the challenge is the shifting of administrative priorities, litigation pressures, and economic tradeoffs.

Looking ahead, 2026 may bring more state-level PFAS legislation, while at the federal level there may be a slowdown.⁷³ By reinforcing the existing federal framework and promoting regulatory stability across administrations, this could aid in the public health disaster the country faces. A coordinated approach could enhance public health protection and provide regulatory certainty that is necessary for long term compliance, innovation, and accountability in addressing PFAS contamination. Public health should not be subject to political winds; rather, the EPA should follow its mission statement “to protect human health and the environment.”⁷⁴

Cover Photo by Ivan Bandura on Unsplash

Brookelynn Stone

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