There is a clock ticking in a federal docket. On July 20, 2026, the public comment period closes on two proposed rules that would reshape PFAS drinking-water protections for a generation. A virtual public hearing is scheduled for July 7, with pre-registration closing July 1. Those are not abstract dates on a regulatory calendar. They are the last formal moments when anyone — a retired teacher in Fayetteville, a water-plant operator in rural Ohio, a parent in Forsyth, Georgia — can go on the record about what should be in their drinking water.
The docket number is EPA-HQ-OW-2025-0654 at regulations.gov. We encourage anyone who cares about this to use it.
What's Actually Happening
The two proposed rules, announced May 18, do different things, and precision matters here.
The first rule would rescind the enforceable limits for four PFAS compounds: GenX (HFPO-DA), PFHxS, PFNA, and the Hazard Index mixture that combines those three with PFBS. These limits — all set at 10 parts per trillion — were finalized in April 2024 as part of the first-ever federal drinking-water standard for PFAS. If this rescission is finalized, there will be no federal floor for these chemicals. None.
The second rule keeps the 4-parts-per-trillion limits for PFOA and PFOS — the two most studied forever chemicals — but extends the compliance deadline from 2029 to 2031 through a new federal exemption framework. Water systems that can demonstrate legitimate procurement, financing, or construction delays can apply for the extra two years.
EPA's stated rationale for rescinding the four limits is procedural: the Biden administration allegedly combined regulatory steps that the Safe Drinking Water Act requires to happen sequentially. The agency says it may re-regulate these compounds "through a lawful process" later. Critics counter that pulling the limits now — with no replacement timeline — leaves millions of people unprotected while lawyers argue about sequencing.
GenX Isn't Hypothetical
Of the four compounds on the chopping block, GenX demands particular attention. This is the chemical that Chemours discharged into the Cape Fear River in North Carolina, contaminating the drinking-water supply for hundreds of thousands of downstream residents. The 2024 federal limit was, in part, a direct response to that crisis.
North Carolina has its own state-level GenX standard, so residents there retain some protection. But most states do not have their own limits for GenX, PFHxS, or PFNA. For residents in those states, the proposed rescission doesn't just change a number on paper — it removes the only legally enforceable standard requiring their water utility to test for and treat these compounds.
That is the practical reality behind the procedural argument. Whatever the merits of the legal reasoning, the human consequence is binary: either there is a federal standard that applies everywhere, or there isn't.
Meanwhile, at the State Level
The widening gap between federal retreat and state action continues to define the PFAS landscape in 2026.
New York is developing soil cleanup standards for PFOA and PFOS, using recent background-level studies. Maine has been steadily tightening its PFAS regulations for years and shows no sign of slowing. Minnesota continues advancing its own comprehensive PFAS framework. The Toxic Release Inventory now includes 205 reportable PFAS for reporting year 2025, with reports due July 1 — meaning the transparency apparatus keeps expanding even as drinking-water limits contract.
The CERCLA hazardous substance designation for PFOA and PFOS — the Superfund-style liability trigger — remains untouched. That designation, retained by EPA in September 2025, is arguably the single most impactful federal PFAS regulation still standing. Industry litigation challenging it in the D.C. Circuit had oral argument in January 2026, with a decision expected later this year.
The emerging picture is one of fragmentation. If you live in a state with its own PFAS standards, you may not notice the federal rollback at all. If you live in a state without them, the only thing standing between your family and unregulated GenX in your water is whether your utility voluntarily chooses to test for and remove it.
The Destruction Question
One genuinely encouraging development deserves mention. In April 2026, EPA released its third interim guidance on PFAS destruction and disposal — and for the first time elevated thermal treatment to third in its ranked list of approved methods, up from sixth in 2024. The agency acknowledged "promising results" from new incineration research while noting ongoing uncertainties about products of incomplete combustion.
Class I underground injection wells and RCRA hazardous waste landfills remain the top two options. Emerging technologies — supercritical water oxidation, electrochemical oxidation, mechanochemistry — are discussed but not yet considered commercially proven at scale. EPA committed to annual updates on this guidance, a meaningful acceleration from the prior three-year review cycle.
This matters because the question of what to do with PFAS once you remove it from water is one of the field's most stubborn problems. You can filter forever chemicals out of drinking water. But if the spent filter media goes to a municipal landfill, you have moved the problem, not solved it. Better destruction pathways are essential infrastructure for any serious remediation effort.
What a Public Comment Actually Does
There is a reasonable cynicism about federal comment periods — the sense that the decision is already made and the public process is theater. That cynicism is sometimes warranted. But the administrative record matters more than people realize.
Federal agencies must respond to substantive public comments. When a rule is challenged in court — and these rules will be challenged, by everyone — the administrative record is the battlefield. Comments that cite specific data, describe specific harm, or identify specific procedural deficiencies become ammunition for or against the rule. A comment from a water-plant operator describing the cost and timeline of treatment-system installation carries different weight than a form letter.
The comment period is not a vote. It is an opportunity to put evidence, experience, and expertise on the record in a way that has legal consequence. That is not nothing.
Where We Stand
EPR Foundation believes in enforceable standards. We believe that pulling four drinking-water limits before completing a replacement process — regardless of the procedural justification — creates a real gap in public health protection. We also believe that well-run water utilities deserve reasonable compliance timelines, and that the two-year extension for PFOA and PFOS is defensible if it prevents rushed, substandard treatment installations.
What is not defensible is rescission without a timeline for re-regulation. "May" is not a commitment. A promise to regulate later, through a lawful process, without a deadline or interim standard, is a gap dressed up as a plan.
If you want to speak to this: July 1 is the pre-registration deadline for the virtual hearing. July 7 is the hearing. July 20 is the written comment deadline. The docket is EPA-HQ-OW-2025-0654 at regulations.gov.
Public comment periods are one of the few mechanisms where individual voices still carry legal weight in federal rulemaking. The window is open. It won't be for long.