The Future of PFAS Regulation

ENVIRONMENT

The Future of PFAS Regulation: Looking Ahead Into 2026

PFAS rules are finally moving from draft to real-world deadlines. The U.S. EPA’s 2024 drinking water standards and the CERCLA listing of PFOA and PFOS reset how utilities, contractors, and site owners must think about these compounds. By 2026, most environmental teams will be juggling new monitoring programs, disposal plans, and liability exposure. This isn’t about hype anymore—it’s basic compliance engineering.

What’s already locked in

U.S. drinking water standards

EPA’s April 2024 rule sets enforceable limits of 4 ng/L for PFOA and PFOS, and 10 ng/L for PFNA, PFHxS, and GenX. For mixtures, there’s a Hazard Index of 1.0. Systems have three years to test and five years to comply. Four parts per trillion is basically zero from an operator’s point of view, so any design that hopes to hit those levels has to be both precise and conservative.

CERCLA designation and reporting

CERCLA now treats PFOA and PFOS as hazardous substances. One pound in 24 hours triggers a federal release report. That may sound small, but filter changeouts or sludge spills could cross that threshold easily. Update spill plans and train staff accordingly.

Standardized methods

EPA’s Method 1633 covers 40 PFAS in wastewater, groundwater, and solids, and will soon be codified in 40 CFR Part 136. Method 1621 provides a screening tool for adsorbable organic fluorine when you need a quick overview.

Disposal guidance

EPA’s updated disposal guidance defines three viable routes:

High-temperature thermal treatment
Deep-well injection
Engineered landfilling with leachate controls

All options carry cost and uncertainty. Plan your waste streams before systems go live.

Canada and the EU

Canada: Health Canada’s treatment objective is 30 ng/L for the sum of 25 PFAS in drinking water. Check provincial implementation before design.
EU: Member States must meet 0.1 µg/L for the sum of 20 PFAS and 0.5 µg/L for PFAS Total by January 12, 2026.

What may still shift

SDWA timeline adjustments

EPA could extend compliance deadlines or narrow its rule scope to PFOA/PFOS only—but don’t plan on it. Keep your capital schedules flexible.

Effluent Guidelines

EPA is targeting 2026 for new PFAS rules in landfills and metal finishing/electroplating. These will shape pretreatment and POTW source control.

TSCA PFAS reporting

TSCA Section 8(a)(7) reporting opens April 13, 2026 and closes October 13, 2026. Even if you’re not a manufacturer, expect ripple effects in supply chains and procurement specs.

Firefighting foams

The Department of Defense will phase out AFFF by October 1, 2026. Fluorine-free foams (F3) are improving but need validation and retrofits. The EU’s foam ban begins in late 2025.

Practical takeaways for engineers

1. Treatment design

Practical design targets and layout choices that save rework later.

Set internal design targets below regulatory limits to create margin. Example targets: 2 ng/L for PFOA/PFOS finished water when the MCL is 4 ng/L. This protects against media variability, startup transients, and lab uncertainty.
GAC: Size for 10–20 minutes empty bed contact time (EBCT) per vessel at firm flow. Use lead–lag trains with sample ports after each vessel. Plan changeout based on breakthrough curves, not just calendar time. Specify reactivation logistics up front.
AIX: Select resin based on site fingerprint (short‑chain vs. long‑chain). Track capacity in bed volumes. Many sites see 20,000–80,000 BV to breakthrough depending on matrix. Provide piping for quick resin swap‑outs and a drain‑down/flush loop.
RO/NF: Hold for complex matrices or when multiple co‑contaminants are present. Assume 75–85% recovery without additional concentrate management. Budget space and power for future RO if you start with GAC/AIX.
Skid and pad: Leave room for at least one extra parallel train. Standardize valve manifolds and use Victaulic or flanged connections to speed media changeouts. Include differential pressure taps and dedicated sample lines.
Instrumentation: Put low‑range conductivity and flow totalizers on each train. Add auto‑composite samplers where permits require time‑weighted samples.

2. Sampling and QA/QC

Reduce false positives/negatives and avoid costly resampling.

Use PFAS‑clean sampling: HDPE or polypropylene bottles, no PTFE tape, no waterproof clothing or cosmetics that can contain fluorinated compounds. Nitrile gloves. New or PFAS‑free coolers and ice packs.
Blanks: Field, equipment, and trip blanks on every sampling event until the team shows consistent control. Label and track blanks like real samples.
Chain of custody: Pre‑fill forms with method codes (e.g., 533/537.1 for finished water, 1633 for wastewater/solids). Require labs to confirm reporting limits below your design targets.
Sample ports: Install dedicated, flushed ports immediately upstream and downstream of each unit process. Avoid sampling from hose bibbs or dead‑legs.
Data review: Create a one‑page checklist for qualifiers, surrogates, and holding times. Refuse data packages that cannot support permitting or design decisions.

3. Residuals and waste

Plan the back end before you turn the front end on.

Inventory waste streams at design: spent GAC, spent resins, spent filters, RO concentrate, backwash water, dewatering filtrate. Size equalization tanks and secondary containment accordingly.
Pre‑qualify outlets: Get conditional approvals from vendors for thermal treatment, deep‑well injection, or engineered landfills. Many vendors require a PFAS profile and moisture content limits before acceptance.
Contract language: Add cradle‑to‑grave handling, manifesting, and tracking requirements. Require certificates of destruction or disposal. Define who pays if a load is rejected.
Dewatering: Provide drain‑down connections on vessels and filters. For RO, design concentrate tanks with vapor‑tight covers, overfill protection, and truck‑loading points.
Leachate interfaces: If your site sends residuals to a POTW or landfill, coordinate early on PFAS monitoring and acceptance criteria.

4. NPDES and pretreatment

Stay ahead of monitoring‑only conditions and sector controls.

Expect permits to add PFAS monitoring using Method 1633 for relevant matrices. Draft a monitoring plan now with locations, frequency, and responsible staff.
POTWs: Map influent sources with a quick survey of likely contributors. Priority sectors include landfills, metal finishing/electroplating, certain chemical manufacturers, and textile/OCPSF users. Set up voluntary industrial monitoring before formal limits arrive.
Source control: Update local limits, haul‑in acceptance, and surcharge programs to reflect PFAS. Require declarations from industrial users on PFAS‑containing fume suppressants, surfactants, and defoamers and suggest alternatives where feasible.
Data management: Build a PFAS tab in your existing LIMS. Keep it simple: analyte list, method, RL, result, qualifiers, sample point.

5. Liability and due diligence

Design scopes and contracts like PFAS will be discovered.

Phase I/II: Add PFAS questions to records reviews and interviews. Include optional PFAS sampling triggers tied to site history.
Specifications: Prohibit non‑essential PFAS‑containing consumables on site. Allow exceptions where safety requires them but require containment and tracking.
Contract clauses: Include sampling protocols, chain‑of‑custody rules, spill reporting within one hour, and allocation of PFAS‑related disposal costs. Flow these requirements to subs.
SPCC/ERP: Add the 1‑lb in 24 hours reporting trigger and provide a call tree. Run a tabletop drill before commissioning.

6. Firefighting systems

Avoid last‑minute foam surprises.

Inventory: Document all AFFF stocks, manufacture dates, and system locations. Tag and segregate legacy concentrates.
Compatibility: Verify proportioners, pumps, and nozzles with fluorine‑free foam (F3). Many systems need recalibration or hardware swaps.
Testing: Plan containment for acceptance and training discharges. Do not discharge foam‑water to storm. Sample and route to treatment or disposal.
Disposal: Reserve take‑back or destruction capacity well before 2026. Build this into bid schedules for ARFF and industrial projects.

7. International alignment

One design standard for multi‑region portfolios reduces churn.

Benchmark: If projects span the U.S., Canada, and the EU, adopt the strictest metric as your internal target. For example, design U.S. systems to achieve ≤2 ng/L PFOA/PFOS even if a Canadian project can meet a higher sum limit.
Documentation: Use a single basis‑of‑design template that lists all regional requirements and your chosen internal target. This streamlines client approvals and submittals.
Supply chain: Require material submittals that declare PFAS content under TSCA definitions. This anticipates 2026 reporting and future procurement specifications.

Short project story: catch PFAS early or pay later

In 2023, our team supported a water plant expansion next to an old training airfield. PFAS never came up in the kickoff because the project was “just” a capacity add. At 60% design, a desktop review flagged historic AFFF use upstream and a nearby landfill taking industrial sludges. We sampled the raw water and saw low‑ppt PFOA/PFOS with short‑chains in the mix. That single data point forced a redesign: add lead–lag AIX ahead of GAC, expand the building footprint, and upsize waste handling. Cost increase: several million dollars. Schedule slip: months. The lesson was simple—put a PFAS history check on your pre‑design checklist for every project near airports, fire training areas, plating operations, textile users, or landfills. If PFAS is not discussed in the first month, it tends to surface at the worst time, when drawings are nearly done and pad space is already tight.

2025–2026 Action Checklist

Pilot testing: Confirm treatment performance and resilience to short-chain PFAS.
Lab selection: Use labs validated on Method 1633; verify detection limits.
Disposal: Prequalify vendors and lock in thermal or injection capacity.
Permitting: Prepare for PFAS monitoring in NPDES permits.
Schedules: Keep both “current” and “extended” compliance timelines ready.
Emergency planning: Update spill plans for the 1-lb CERCLA RQ and train operators.
Foam transition: Retrofit systems and secure disposal logistics before deadlines.

What to watch through 2026

Possible revisions to EPA’s drinking water rule
PFAS Effluent Guidelines for landfills and metal finishing
TSCA reporting outcomes in late 2026
Updated disposal guidance and new destruction technologies

Bottom line

By 2026, PFAS management will be routine in design work. The job isn’t just detection—it’s removal, tracking, and liability control. Design conservatively, sample cleanly, plan disposal early, and assume scrutiny will increase, not fade.