On January 21, 2025, the U.S. Environmental Protection Agency’s (EPA) proposed rule seeking to set effluent limitation guidelines for certain per- and polyfluoroalkyl substances (PFAS) under the Clean Water Act (CWA) was withdrawn from Office of Management & Budget (OMB) review following President Trump’s Executive Order implementing a regulatory freeze. Federal action may be halted, but states are beginning to enact legislation that seeks to address PFAS contained in industrial effluent. These laws are currently sparse, with Maryland being the most recent state to establish a robust framework that requires industrial sources to limit PFAS in effluent. A handful of other states have laws establishing monitoring and reporting protocols for PFAS in industrial effluent, and other states have similar frameworks planned for future implementation. While these efforts are not yet widespread, heightened scrutiny of PFAS use suggests that more and more states will seek to monitor and limit PFAS in industrial effluent. For more information, please read our full memorandum.

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