What’s Ahead for PFAS Regulation: December Watchlist

Clean Water Act and NPDES PFAS Permits

EPA has also signaled plans to expand PFAS coverage under the National Pollutant Discharge Elimination System (NPDES). Draft language is expected that would add PFAS monitoring and reporting to certain wastewater and industrial discharge permits.

In some regions, states are already putting PFAS into individual permits or using ad hoc information requests. A national framework will not erase those efforts overnight. It will give regulators a more consistent way to ask who is discharging which PFAS and at what levels.

What this could mean in practice

For facilities with NPDES permits and the consultants who support them:

• Inventory where PFAS can enter waste streams. Think firefighting foams, surface treatments, cleaners, metal finishing, textile treatments, leachate, and industrial inputs.
• Talk with your lab about capacity and methods before PFAS language appears in your permit. Scrambling after the fact rarely goes well.
• Watch for state-specific guidance, since some state programs may move faster than the federal language.

Early adopters will be facilities that already understand their PFAS sources and can respond quickly when regulators ask for a monitoring plan.

Safe Drinking Water Act PFAS Standards

EPA’s national PFAS drinking water rule set maximum contaminant levels (MCLs) for several PFAS and created a hazard index for mixtures. Since finalization, there has been active debate over timelines and over how many of those PFAS will remain in their current form.

Current discussions include two major pieces:

• Extending the compliance deadline for PFOA and PFOS, giving drinking water systems more time to design, fund, and install treatment.
• Reconsidering the MCLs for the other PFAS covered by the rule, which could lead to revisions or rescinding some of those standards depending on the final analyses and political pressure.

On paper, schedule changes look like breathing room for utilities. In reality, they also extend the period when communities are drinking water that is known to be contaminated, and they complicate planning because the target may move again.

What this could mean in practice

For drinking water utilities, engineering firms, and state programs:

• Keep moving forward on PFAS assessment and planning even if the deadline shifts. Treatment media, engineering time, and lab capacity do not appear overnight.
• Run scenarios. What happens if all MCLs stay in place. What if only PFOA and PFOS remain. How would that change which wells or entry points you treat first.
• Communicate clearly with boards and customers. “We are tracking the changes and still moving toward lower PFAS in your water” lands better than “we will wait and see.”

Looking Ahead

If these PFAS actions land in December, 2026 will be less about whether PFAS are regulated and more about which program hits first and how to manage overlapping requirements.

For labs, that means pressure on turnaround time and reporting format, not just on detection limits. For utilities and industry, it means aligning TSCA reporting, discharge permits, and drinking water obligations so they do not conflict or overload the same team.

Organizations that will be best prepared are the ones that:

• Map where PFAS shows up in their systems today.
• Build flexible sampling and data workflows they can scale when rules finalize.
• Work with labs and technical teams who can explain what the data actually shows, not just deliver a spreadsheet.

PFAS policy will keep shifting, no matter who is in charge in D.C. If you know your PFAS footprint and have a realistic plan for sampling, analysis, and communication, you will be ready when the next round of rules lands.