Table of Contents

1. Executive Summary

2. Global PFAS Regulatory Timeline & Status

3. U.S. EPA PFAS Rules: The Technical Deep Dive

4. Global Regulatory Comparison

5. PFAS Drinking Water Standards by Jurisdiction

6. State-Level PFAS Bans: The Fragmented U.S. Landscape

7. Industry-Specific Impacts & Compliance Requirements

8. PFAS Testing Methods: From 537 to 537.1

9. Compliance Checklist & Action Steps

10. Future Trends & Pending Proposals

11. Resources & Interactive Tools

The global PFAS regulatory landscape has fundamentally shifted in 2025, driven by PFAS regulations 2025 and rapid policy acceleration worldwide. The U.S. EPA has finalized drinking water standards, released PFAS EPA 2025 final rules, extended TSCA reporting deadlines to April 2026, and is now proposing major revisions to the scope of reporting requirements in line with PFAS EPA rules. The EU is moving toward a near-total PFAS ban under REACH 2.0, while state-level bans in the U.S. are creating a fragmented patchwork that affects product access to markets like California, Minnesota, and Illinois—an environment that demands constant monitoring of global PFAS regulations update developments. Manufacturers must act immediately to comply with PFAS compliance 2025 obligations and evolving state-level mandates.

The global shift is also being accelerated by the latest PFAS drinking water standards, especially since the U.S. EPA has finalized enforceable limits under the National Primary Drinking Water Regulation. These PFAS drinking water standards have significant impacts on public water systems and industrial users globally. With multiple jurisdictions announcing stricter thresholds, organizations must track every global PFAS regulations update and adjust their supply chains to remain compliant. Many companies are now preparing early for April 2026 reporting and aligning with PFAS EPA rules requirements to avoid penalties under the PFAS EPA 2025 final rules framework.

As part of risk mitigation, manufacturers must also review remediation requirements linked to the latest PFAS drinking water standards and strengthen internal programs to meet PFAS compliance 2025 expectations. The urgency is driven by widespread regulatory tightening, and organizations should ensure readiness for both current and upcoming PFAS regulations 2025 obligations.

Global PFAS Regulatory Landscape Timeline & Status

Key Milestones

U.S. EPA PFAS Rules: The Technical Deep Dive

The TSCA PFAS Reporting Rule:

Effective Date: November 13, 2023

Revised Reporting Period: July 11, 2025 – January 11, 2026 (most companies); July 11, 2025 – July 11, 2026 (small businesses)

Scope: Covers 205 reportable PFAS chemicals

Who Must Report?

Mandatory reporters include:

• Manufacturers of PFAS chemicals

• Importers of PFAS-containing products (including finished goods, articles, mixtures)

• Processors of PFAS-containing materials

• Key expansion: The rule applies to "articles" (finished products), not just raw chemicals—this affects packaging suppliers, textiles manufacturers, electronics companies, and food service providers

Exemptions (very limited):

• Pure polymers (generally PFAS-based fluoropolymers like PTFE)

• Articles imported in quantities of less than 100 lbs per year

• De minimis uses below the reporting threshold (though EPA has proposed narrowing this exemption)

What Must You Report?

For each reportable global PFAS regulatory landscape chemical, manufacturers and importers must submit:

1. Chemical Identity:

   • CAS Registry Number

   • Chemical name(s)

   • Synonyms

2. Production Volume Data (2011–2022 historical period):

   • Domestic manufacturing volume (pounds)

   • Import volume (pounds)

   • Byproduct volume (pounds)

   • Total byproduct production

3. Use Information:

   • Industrial function(s) or use(s)

   • Product categories containing the PFAS

   • Production/manufacturing methods

   • Environmental release estimates

4. Exposure Data:

   • Worker exposure (occupational)

   • Consumer exposure pathways

   • Environmental release data

   • Disposal method(s)

5. Health and Safety Studies:

   • Citations to any available epidemiological or health effect studies

   • Environmental fate and toxicity data

The Reporting Process

Step 1: Gather Historical Data

• Compile all manufacturing, import, and processing records from 2011 to 2022

• Document global PFAS regulatory landscape content in products, byproducts, and waste streams

Step 2: Categorize Reportable PFAS

• Identify which of the 205 reportable PFAS are present in your products/processes

• Determine concentration levels (no de minimis exemption for most)

Step 3: Register and Access the EPA Portal

• Create an account on the EPA's Central Data Exchange (CDX)

• Complete company registration and contact information

• Receive credentials for data entry

Step 4: Submit Data

• Use the EPA's web form or bulk upload templates

• Ensure data accuracy (EPA cross-checks with other regulatory databases)

• Submit by the deadline (January 11, 2026, for most; July 11, 2026, for small businesses)

Step 5: Maintain Records

• Retain all supporting documentation for 3 years

• EPA may request additional documentation for verification

Penalties for Non-Compliance

National Primary Drinking Water Regulation (NPDWR) for PFAS

Rule Finalized: April 2024 (EPA finalized first-ever enforceable limits)

Compliance Timeline: Phased through 2031

Maximum Contaminant Levels (MCLs) by Chemical

Hazard Index Formula: (PFNA conc./10) + (PFHxS conc./10) + (GenX conc./10) + (PFBS conc./10) = Hazard Index. In case, the index goes beyond 1.0, the system exceeds the standard.

Key Compliance Phases

Phase 1 (2027): Public water systems must begin initial PFAS monitoring and consumer notification

Phase 2 (2029): If MCLs are exceeded, systems must implement treatment/mitigation

Phase 3 (2031): Full compliance deadline (extended from 2029)

Global PFAS Regulatory Landscape Comparison

Table: Global PFAS Regulatory Framework (2025)

PFAS Drinking Water Standards by Jurisdiction

Detailed Comparison Table: What Are the MCLs in Your Region?

State-Level PFAS Bans: The Fragmented U.S. Landscape

The Critical Challenge for Manufacturers: No single federal product ban exists. Instead, a patchwork of state regulations creates market access barriers and compliance complexity.

State-by-State Ban Summary (as of December 2025)

Key Implications for Manufacturers

1. Immediate Compliance Risk (Active Since Jan 1, 2025):

   • California textile bans (100 ppm limit)

   • Minnesota (11 product categories)

   • Illinois (food packaging)

   • Oregon (foam packaging)

   • Washington (priority consumer products with ongoing annual reporting)

2. Coming Soon (2026–2028):

   • Maine full ban (unless CUU exemption granted; currently reviewing requests)

   • Minnesota phase 2 & 3 expansions

   • Connecticut expanded ban (July 1, 2026)

   • New Mexico ban (Jan 1, 2028)

3. Supply Chain Strategy:

   • Must maintain separate product lines for compliant (PFAS-free) vs. non-compliant markets

   • Suppliers of raw materials must be screened for unintentional PFAS contamination

   • Document all PFAS certifications and testing data

Industry-Specific Impacts & Compliance Requirements

1. Food Packaging & Foodservice Industry

Regulations Affecting This Sector:

• California, Minnesota, Illinois, Oregon, Washington bans on foam and PFAS-treated packaging

• FDA clearance of certain PFAS for food-contact uses (creates conflict with state bans)

Compliance Actions Required:

• Audit all food-contact materials for PFAS content

• Obtain Certificates of Compliance (CoCs) from suppliers confirming PFAS-free status

• Switch to alternatives: bagasse containers, kraft paper, PLA, compostable CPLA cutlery

• Implement testing to EPA Method 8081B (or equivalent) to verify PFAS absence

Cost Impact: $50K–$500K for reformulation and testing

2. Textiles & Apparel Industry

Regulations Affecting This Sector:

• California 100 ppm limit for intentionally added PFAS (Jan 1, 2025)

• Minnesota fabric treatment ban (Jan 1, 2025)

• Washington annual reporting requirement

• Colorado phase 2 (Jan 1, 2028): broader textile restrictions

Compliance Actions Required:

• Test raw fabrics and finished garments for PFAS content (EPA Method 537.1 or equivalent)

• Discontinue use of PFAS-based water/stain repellents

• Switch to PFAS-free alternatives (e.g., silicone-based, wax-based treatments)

• Maintain CoCs from fabric suppliers

• Develop state-specific product lines if necessary

Cost Impact: $100K–$1M+ for reformulation, testing, and supply chain management

3. Medical Devices & Pharmaceuticals

Regulations Affecting This Sector:

• FDA has declared fluoropolymers (PFAS) in medical devices "safe and currently irreplaceable" (Aug 2025)

• Most state bans include medical device exemptions (though language varies)

• EU REACH ban will require exemption applications for medical uses

Compliance Actions Required:

• Document FDA approval/authorization for any PFAS-containing medical devices

• Maintain medical device exemption status under state laws (coordinate with legal counsel)

• For EU market: prepare exemption applications under REACH for essential medical uses

• Monitor EU guidance on medical device exemptions (ongoing as of Dec 2025)

Cost Impact: Legal/regulatory consultation: $50K–$200K; potential reformulation if exemptions denied: $500K+

4. Electronics & Semiconductor Manufacturing

Regulations Affecting This Sector:

• EPA TSCA reporting for any PFAS-containing components or manufacturing processes

• EU REACH ban affects supply chain sourcing

• No specific state bans on electronics (yet), but potential future action

Compliance Actions Required:

• Audit all electronic components for PFAS (particularly in insulation, coatings, adhesives)

• Report to EPA TSCA if PFAS content above 0.1% (deadline Jan 11, 2026)

• Source PFAS-free alternatives where possible

• Maintain detailed supplier declarations and testing data

Cost Impact: Audit/reporting: $25K–$100K; potential component substitution: $100K–$1M+

5. Manufacturing Processes & Byproducts

Regulations Affecting This Sector:

• EPA TSCA reporting for byproduct PFAS and process chemicals

• Any facility using PFAS as a manufacturing aid must report

Compliance Actions Required:

• Identify all PFAS-containing process chemicals (lubricants, mold releases, surfactants)

• Document byproduct generation and disposal methods

• Report to EPA TSCA (deadline Jan 11, 2026)

• Evaluate process modifications to eliminate PFAS use

Cost Impact: Process assessment: $10K–$50K; reporting: $5K–$25K; process modification: $50K–$500K+

PFAS Testing Methods: From 537 to 537.1

EPA Method 537.1: The Standard for Drinking Water Analysis

What It Is: The gold-standard analytical method for detecting PFAS in drinking water

Analytes Detected: 18 PFAS compounds (expanded from original 537, which detected 14):

• PFOA, PFOS, PFHxS, PFNA, PFBA, PFBS

• PFDA, PFDoA, PFHxA

• PFDA, PFUnA, PFDiA

• HFPO-DA (GenX), 9Cl-PF3OUdS, 11Cl-PF3OUdS, 8:2 FTS, 10:2 FTS

Detection Limit: As low as two ppt (parts per trillion) for most analytes

Procedure Overview:

1. Sample Collection: Use PFAS-free plastic containers (Teflon-lined or pre-cleaned); avoid cross-contamination

2. Solid-Phase Extraction (SPE): Extract PFAS from water sample using specially conditioned cartridges

3. LC-MS/MS Analysis: Analyze extracted compounds using liquid chromatography tandem mass spectrometry

4. Quality Control: Include field blanks, matrix spikes, duplicates (required at 5% minimum frequency)

Typical Lab Cost: $300–$800 per sample

Turnaround Time: 5–10 business days

Accreditation: Must be performed by EPA-certified or state-accredited laboratories

Alternative Methods & Emerging Technologies

Compliance Checklist & Action Steps

Immediate Actions (December 2025)

Step 1: Audit Your Supply Chain (Weeks 1–4)

• Identify all suppliers of PFAS-containing materials, chemicals, or finished goods

• Request CoCs (Certificates of Compliance) confirming PFAS-free status

• Document any intentional PFAS use in products, processes, or manufacturing aids

• Assess for unintentional PFAS contamination (recycled materials, impurities)

Step 2: Determine Your EPA TSCA Reporting Obligation (Weeks 1–2)

• Review the 205 reportable PFAS chemicals on the EPA list

• Determine if your company fits the definition of "manufacturer," "importer," or "processor"

• If yes: You must report by January 11, 2026 (or July 11, 2026 if small business)

• Estimate reporting effort: typically 2–8 weeks depending on product complexity

Step 3: Verify State Ban Compliance (Weeks 2–4)

• Cross-reference your product categories with state-specific bans (California, Minnesota, Illinois, Oregon, Washington, Maine, Colorado, Connecticut, Vermont, New Hampshire, New Mexico, New York proposed)

• For affected products: either reformulate to PFAS-free OR document "currently unavoidable use" (if applicable in your state)

• Obtain testing data proving PFAS-free compliance or CUU exemption

Step 4: Prepare EPA TSCA Reporting Package (Weeks 3–12)

• Compile historical data (2011–2022):

  • Production volumes (domestic manufacturing)

  • Import volumes and source countries

  • Byproduct generation and disposal

  • Exposure pathways (worker, consumer, environmental)

  • Available health/safety studies

• Organize data by PFAS chemical

• Prepare for EPA portal submission

Step 5: Register for EPA Central Data Exchange (CDX) (Week 4)

• Go to **https://www.epa.gov/cdx**

• Create a company account and register for PFAS reporting

• Obtain portal credentials

• Confirm data submission capability

Step 6: Test Products for PFAS Content (Ongoing)

• For suspected PFAS-containing products: engage accredited laboratory for EPA Method 537.1 (drinking water) or equivalent methods (products, textiles, soil)

• Budget $300–$800 per sample for comprehensive analysis

• Maintain test results for regulatory records

Medium-Term Actions (January–April 2026)

Step 7: Submit EPA TSCA Report (Deadline: January 11, 2026)

• Log in tothe EPA CDX portal

• Complete all required data fields per reporting instructions

• Submit electronically before 11:59 PM ET on the deadline

• Retain confirmation receipt and all supporting documentation

Step 8: Prepare for Regulatory Inspection/Audit

• Maintain 3-year record retention policy

• Develop internal audit trail for data submitted to EPA

• Ensure compliance with state-level reporting requirements (e.g., California product notification, Minnesota phase 2 reporting)

Step 9: Engage Legal Counsel on State Exemptions (if applicable)

• If your products are affected by state bans: evaluate "currently unavoidable use" exemptions (Maine, Colorado, Connecticut, Washington)

• Submit exemption requests with supporting documentation

• Timeline varies by state; some deadlines are approaching

Long-Term Strategic Actions (2026–2031)

Step 10: Reformulate for PFAS-Free Alternatives

• Conduct R&D on PFAS-free substitutes:

  • For water/stain repellents: silicone-based, wax-based, fluorine-free polymers

  • For non-stick coatings: ceramic coatings, sol-gel technologies

  • For firefighting foams: fluorine-free aqueous film-forming foams (AFFF)

• Budget: typically $100K–$1M+ depending on product complexity

• Timeline: 1–3 years for market-ready alternatives

Step 11: Establish Compliance Monitoring System

• Implement automated tracking for regulatory changes in all 50 states + federal level

• Subscribe to regulatory alerts (EPA, state environmental agencies)

• Conduct quarterly compliance audits of product portfolios

• Maintain supplier scorecard for PFAS risk

Step 12: Prepare for Drinking Water Compliance (2027–2031)

• If you operate a public water system: begin PFAS monitoring by 2027

• Budget for activated carbon or ion exchange treatment systems

• Typical cost: $50K–$500K+ per system

• EPA PFAS OUT Program offers technical assistance (free)

Future Trends & Pending Proposals

2026: EPA TSCA Scope Changes (Pending)

Current Status: EPA published proposed rule on November 13, 2025; public comment period closed December 29, 2025

Proposed Changes:

• Narrow the definition of "article" to reduce reporting burden on downstream manufacturers/importers of finished goods

• Expand de minimis exemption for PFAS below certain concentration thresholds

• Clarify scope for importers to distinguish between manufacturers and distributors

Implication: If adopted, some manufacturers may be relieved of reporting obligations; others may face stricter scrutiny. Final rule expected spring 2026.

2026: EU REACH PFAS Restriction Finalization

Current Status: ECHA Background Document published August 20, 2025; sector-by-sector evaluation ongoing

Expected Milestones:

• Q1 2026: Risk Assessment Committee (RAC) and Socio-Economic Analysis Committee (SEAC) finalize opinions

• Q2 2026: European Commission proposes final restriction regulation

• Q4 2026: Member States vote on final regulation

Likely Outcome:

• Restriction Option 2 (RO2) most probable: Phase-in restrictions by sector with transition periods (5–12 years)

• Essential uses exempted: medical devices, pharmaceuticals, aerospace, military applications

• Firefighting foam already subject to October 2030 ban (with transitional periods through 2035)

Implication: EU-based manufacturers and importers must prepare exemption dossiers NOW for any PFAS-containing products claiming "essential use" status.

2026: State-by-State Exemption Determinations

Current Status: Maine, Colorado, Connecticut, and Washington actively reviewing "currently unavoidable use" (CUU) exemption requests

Expected Actions:

• Maine: Likely to grant CUU exemptions for specific medical devices, aerospace components by mid-2026

• Minnesota: Phase 2 reporting requirements activate January 1, 2026; phase 3 full ban framework clarified by mid-2026

• California: Likely to propose exemptions for medical devices and select industrial uses by Q2 2026

Implication: Manufacturers with products affected by state bans should submit exemption requests IMMEDIATELY if not already submitted.

2027–2031: Drinking Water Treatment Deployment

Key Milestones:

• 2027: Public water systems must complete initial PFAS monitoring (EPA Method 537.1 or equivalent)

• 2028–2029: Systems exceeding MCLs for PFOA/PFOS (4 ppt) must implement treatment

• 2031: Full compliance deadline (extended from 2029)

Treatment Technologies:

• Granular activated carbon (GAC): most common; ~$50K–$200K for small systems

• Ion exchange: effective for high-PFAS systems; $100K–$500K

• Advanced oxidation (ozone, UV/H₂O₂): emerging technology; $200K–$1M for large systems

Implication: Water system operators should budget for treatment capital investments NOW; engineering firms specializing in PFAS remediation are in high demand.

2028–2032: Class-Based Regulation Debate

Scientific Debate Ongoing:

• Should regulators ban all PFAS as a chemical class (class-based approach) or regulate individually (compound-specific)?

• Arguments for class-based: simpler implementation, prevents manufacturers from swapping one PFAS for another unregulated substitute

• Arguments against: unintended consequences for medical devices, aerospace, and other essential uses where alternatives unavailable

Expected Actions:

• EPA likely to propose class-based reporting framework by 2028

• EU may move toward class-based restrictions if sector-specific approach proves insufficient

• Maine, California, other states may adopt class-based language in upcoming legislative sessions

Implication: Manufacturers should prepare for worst-case scenario where ALL PFAS are restricted; invest in truly PFAS-free alternatives NOW.

Certivo Compliance Solution

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• State Compliance Matrix: Automated guidance for product compliance across all 50 states

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The Time to Act Is Now

The global PFAS regulatory landscape in 2025 is defined by urgency, fragmentation, and evolution. The U.S. EPA TSCA reporting deadline (January 11, 2026) is just around the corner, state-level bans are already eliminating market access for non-compliant products, and the EU's REACH ban is reshaping entire supply chains.

Manufacturers who act proactively today—by auditing supply chains, reporting to EPA, securing state exemptions, and reformulating for PFAS-free alternatives—will emerge as industry leaders. Those who wait risk market exclusion, regulatory penalties, and irreversible brand damage.

The window to comply is narrowing. Your next step is clear: begin your PFAS compliance audit today, engage regulatory counsel where needed, and deploy a platform (like Certivo) that can automate the complexity.

The future of manufacturing compliance is here. Are you ready?