PFAS in water
Reporting Year 2025 Toxics Release Inventory (TRI) filings were due on Wednesday, 1 July 2026, marking the first full reporting cycle to include nine PFAS added to the programme under a 2025 rule.
The timing puts monitoring and analytical laboratories in an unusual position: required to report on more PFAS than ever, while EPA simultaneously proposes to roll back some of the drinking water standards covering related substances.
EPA finalised the addition of the nine PFAS in January 2025, acting under a statutory requirement in the 2020 National Defense Authorization Act.
The rule took effect in February 2025, making the nine substances reportable for the first time in Reporting Year 2025.
That brings the number of PFAS reportable under TRI for Reporting Year 2025 to 205.
A further substance, PFHxS-Na, became reportable from Reporting Year 2026 onwards, taking the programme's running total to 206 – a distinction worth keeping straight, since the two figures describe different reporting years.
PFAS are also designated Chemicals of Special Concern under TRI. That removes the usual de minimis exemption, so facilities must track and report PFAS even in trace amounts, provided they exceed the 100 lb per year activity threshold.
Suppliers must also disclose PFAS content in products regardless of concentration.
On Tuesday, 7 July 2026, EPA held a virtual public hearing on two proposed rules affecting PFAS in drinking water.
The first, a compliance extension rule, would keep the existing 4.0 ppt maximum contaminant levels for PFOA and PFOS but give eligible water systems an additional two years, until April 2031, to comply.
The second, a rescission rule, would withdraw the regulatory determinations and enforceable limits for PFHxS, PFNA and GenX, along with a combined Hazard Index limit covering those three plus PFBS.
EPA's stated basis for the rescission is procedural: the agency argues its 2024 rule improperly proposed and finalised regulatory determinations for those four substances at the same time.
Administrator Lee Zeldin has framed the move as leaving room for tighter rules later, saying the substances "might warrant strict standards, possibly even stricter than what was previously regulated."
Occurrence data help explain EPA's differentiated approach.
Analysis of national monitoring data found exceedances for PFHxS, PFNA and GenX affecting well under one per cent of monitored water systems, compared with 8 to 9% for PFOA and PFOS.
The written comment period on both proposals closes on Monday, 20 July 2026.
For laboratories and instrument suppliers, the two developments pull in different directions.
Expanded TRI reporting increases demand for PFAS detection and quantification capability across a wider substance list, including compounds with lower historical testing volumes.
A scaled-back drinking water standard for four of those substances could, over time, dampen demand for compliance monitoring specifically tied to enforceable limits – though TRI reporting obligations are unaffected by the drinking water proposals, since the two programmes operate under separate statutes.
The safe drinking water anti-backsliding provision is central to how this plays out.
It requires that any revision maintain, or improve on, existing protection levels, and legal commentators note the provision has not previously been tested in court.
Litigation challenging the underlying 2024 rule is already under way, adding further uncertainty for utilities and their laboratory partners planning testing programmes around either outcome.
Reporting and regulation are moving in opposite directions for the same family of compounds, and monitoring providers are exposed to both.
Laboratories should expect sustained or growing demand for broad PFAS analytical capability under TRI, regardless of how the drinking water rulemaking concludes.
IET 36.3 May
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