Protect People · Restore Land & Water · Build America Right
← All Posts
July 3, 2026  ·  Field Note

Field Note: The Week the Clock Started

July 1 was the most consequential single day for PFAS policy in 2026 so far — not because of one headline, but because a half-dozen deadlines, awards, and rules all landed at once. Here is what actually happened.

If you follow PFAS policy for a living, this week felt like watching five different chess games reach endgame simultaneously. July 1, 2026, was not one event. It was a convergence — settlement dollars finally hitting the ground in Minnesota, new state product laws snapping into effect in Connecticut and New Jersey, EPA proposing to monitor chemicals it has never tracked before, and the quiet expiration of a claims deadline that may have left billions of dollars on the table. By Friday, the landscape looks different than it did a week ago.

Minnesota Shows What Settlement Money Can Actually Do

On July 1, the Minnesota Department of Natural Resources and the Minnesota Pollution Control Agency announced $20 million in awards to 26 habitat restoration and outdoor recreation projects across the Twin Cities east metropolitan area and downstream reaches of the Mississippi and St. Croix rivers. The funding comes from Priority 2 of the state's 2018 Natural Resource Damage Assessment settlement with 3M — the same settlement that provides approximately $800 million under Priority 1 for drinking water treatment in communities contaminated by PFAS from 3M's manufacturing operations.

This matters beyond Minnesota. In a season when the Chemours settlement in North Carolina has drawn criticism for letting the polluter choose which projects to fund, Minnesota is demonstrating a different model: state co-trustees selecting proposals through a structured grant process developed in consultation with government, industry, and resident work groups. DNR Commissioner Sarah Strommen described the awards as "an important step in mitigating that damage by restoring habitat and outdoor spaces that support both people and wildlife."

Twenty million dollars is a fraction of the $800 million dedicated to drinking water. But it is real money going to real projects chosen through a transparent process. That is rarer than it should be.

EPA Will Monitor Ultrashort PFAS — But Not Microplastics

Also on July 1, the Federal Register published EPA's proposed sixth Unregulated Contaminant Monitoring Rule, known as UCMR-6. The rule would require public water systems to collect data on 30 unregulated chemicals, including — for the first time — seven ultrashort-chain PFAS compounds such as trifluoroacetic acid (TFA). The list also includes three pesticide metabolites, 13 semivolatile organic compounds, and seven purgeable organic compounds.

The inclusion of ultrashort PFAS is significant. These are the smallest molecules in the PFAS family — often just two or three carbon atoms — and they are among the hardest to remove from water using conventional treatment. TFA in particular is ubiquitous in the environment and has been detected in drinking water at levels far exceeding those of better-known compounds like PFOA. Monitoring is the first step toward understanding how widespread ultrashort PFAS contamination really is.

But the rule also has a conspicuous absence: microplastics. Seven governors, 15 attorneys general, and 176 organizations had urged EPA to include microplastic monitoring. The agency had even added microplastics to its Contaminant Candidate List in April 2026 and publicly pledged to "protect Americans" from what it called "one of the most urgent and growing public health challenges." Then it left microplastics out of the monitoring rule.

The Plastics Industry Association praised the exclusion as reflecting "the current state of the science." The Plastic Pollution Coalition called it "a serious failure to protect public health." Katie Pelch of the Natural Resources Defense Council noted a more technical concern: the reporting limits for the ultrashort PFAS that were included may be set too high, potentially underestimating contamination levels — the same problem that plagued the third UCMR's original PFAS monitoring a decade ago.

Comments on the proposed rule are due August 31, with virtual public meetings on August 11 and 12.

State Product Laws Go Live

While the federal government debates what to monitor in water, states are moving to control what goes into products. July 1 marked the effective date for Connecticut's requirement that manufacturers provide written notification before selling or distributing products containing intentionally added PFAS — including cosmetics, apparel, and other consumer goods. New Jersey's parallel PFAS labeling and ban requirements are also taking effect.

Meanwhile, Minnesota loosened its PFAS product reporting requirements on May 26, exempting products manufactured before July 1, 2023 — a concession to manufacturers dealing with legacy replacement parts. And in Pennsylvania, House Bill 2145 passed the state House 188–13 on June 8, proposing to ban PFAS in juvenile products, cosmetics, dental floss, and menstrual products by January 2028. It now heads to the Senate.

The patchwork is thickening. Each state draws its lines differently — some ban, some label, some report, some exempt. For manufacturers selling nationally, compliance is becoming a state-by-state puzzle. For consumers, protection depends entirely on where you live.

Monday's Hearing and the Comment Window

All of this is backdrop to what happens next. On Monday, July 7, EPA holds a virtual public hearing on its proposed rules to rescind drinking water limits for four PFAS chemicals — GenX, PFHxS, PFNA, and the Hazard Index mixture — and to extend the PFOA and PFOS compliance deadline from 2029 to 2031. The public comment period closes July 20.

The CERCLA hazardous substance designation for PFOA and PFOS remains intact. The TRI reporting list has grown to 205 reportable PFAS. EPA's updated destruction and disposal guidance has elevated thermal treatment in its rankings. The regulatory architecture is not collapsing — it is fracturing along federal-versus-state lines, with different agencies moving at different speeds in different directions.

What We Are Watching

This week's convergence tells a specific story. The federal government is simultaneously expanding monitoring (UCMR-6), holding firm on liability (CERCLA designations), pulling back on enforceable limits (drinking water MCLs), and deferring on emerging threats (microplastics). States are simultaneously tightening product rules, deploying settlement funds, and in some cases narrowing the legal tools available to local governments. There is no single direction. There is a dozen directions at once.

At EPR Foundation, we think the Minnesota model deserves attention. Settlement money that sits in escrow protects no one. Grant programs with transparent selection processes, resident input, and public accountability turn dollars into habitat, clean water, and restored land. That is what "restoration" means when it is more than a press release.

If you have standing to comment on either the UCMR-6 monitoring rule (due August 31) or the PFAS drinking water rollback (due July 20), do it. These comment periods are not performative. They are the formal record that regulators — and courts — will reference for years.

Sources: Minnesota DNR, "3M PFAS Settlement Project Awards Announced" (July 1, 2026); EPA UCMR-6 proposed rule, Federal Register (July 1, 2026); C&EN, "EPA Omits Microplastics from Water-Monitoring Rule" (July 1, 2026); Ballard Spahr, "EPA Rolls Back PFAS Regulations, States Fill the Gap" (June 2026); DLA Piper, "2026 Mid-Year PFAS Update" (June 2026); McGuireWoods, "Contaminants Compass: June 2026 Edition"; EPA Proposed PFAS Rescission Rule (epa.gov, May 2026).

← When Washington Retreats: The States Stepping Up on PFAS The Great Substitution: How Industry Is Finally Replacing Forever Chemicals with Safer Chemistry →