On September 4, 2025, the U.S. Environmental Protection Agency announced over 100 actions as part of its upcoming regulatory agenda. These plans were included in the White House’s semiannual “Unified Agenda of Regulatory and Deregulatory Actions,” in which every federal agency announces what rulemakings will be prioritized in the near future.

The general theme of these actions was deregulation, as has long been promised by the Trump administration. These regulatory actions come as part of President Trump’s initiative to “unleash American energy,” and generally seek to improve efficiency by streamlining environmental permitting, rolling back many Biden-era proposals, and generally reducing the regulatory burden. These changes affect several areas, including PFAS regulations, waste management, water, and climate.

PFAS

• EPA is currently considering public comments as it develops a final rule adding nine specific PFAS substances, their salts, and their structural isomers to the list of hazardous constituents under the Resource Conservation and Recovery Act (RCRA). If finalized, this would require these PFAS substances to be expressly identified for consideration when completing assessments under the RCRA.
• EPA is proposing additional time for public water systems to meet the compliance deadlines for maximum contaminant levels in the National Primary Drinking Water Regulations for PFAO and PFOS, intending to address compliance challenges to the rule while ensuring the long-term protection of PFAS-contaminated drinking water.
• EPA is proposing to revise existing Organic Chemicals, Plastic, and Synthetic Fibers Effluent Limitations Guidelines and Standards (40 CFR part 414) to address per- and polyfluoroalkyl substance discharges from facilities manufacturing PFAS.
• EPA is proposing to update the National Pollutant Discharge Elimination (NPDES) permit application for the first time since 1987, seeking to address monitoring and reporting of PFAS.
• EPA is developing a final action to add individually listed PFAS substances and categories to the Toxics Release Inventory (TRI) list of toxic chemicals subject to reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA) and the Pollution Prevention Act (PPA). EPA will consider how to address PFAS compound categories and what events may trigger the automatic addition of a PFAS to the TRI.
• EPA intends to withdraw its regulatory determinations to regulate four PFAS substances (PFHxS, PFNA, HFPO-DA, and PFBS) under the Safe Drinking Water Act. Further, the EPA intends to rescind all associated regulatory provisions in 40 CFR parts 141 and 142 that are exclusively to these four PFAS.

Waste Management

• EPA is looking to make amendments to the Resource Conservation and Recovery Act Subtitle C standards, which govern hazardous waste generators, transporters, treatment, storage, and disposal facilities. EPA will be specifically looking to solicit public input on topics related to RCRA Subtitle C permitting and permitting reform during this process.
• EPA is finalizing its proposed rule to eliminating the Clean Air Act (CAA) title V permitting requirements for air curtain incinerators (ACI) used by Large Municipal Waste Combustor (LMWC) that only burn wood waste, clean lumber, yard waste, or a mixture of those, and are not located at title V major sources or subject to title V for other reasons.

Water

• EPA, along with the U.S. Department of the Army, is undertaking a rulemaking to amend the regulation’s “waters of the United States” definition in light of the Supreme Court’s decision in Sackett v. Environmental Protection Agency, 598 U.S. 651 (2023).
• EPA is developing a National Primary Drinking Water Regulation (NPDWR) for perchlorate under the authority of the Safe Drinking Water Act (SDWA). EPA expects to issue a proposed rule by November 21, 2025, and a final rule by May 21, 2027.
• EPA is looking to review its 2023 rule implementing Section 401 of the CWA that implements states’ and tribes’ authority to enforce water quality certifications. EPA says it plans to propose a revision by December that would “increase transparency, efficiency, and predictability for co-regulators and the regulated community.”

Climate Change

• EPA is considering rescinding its 2009 finding that greenhouse gas emissions from motor vehicles pose a danger to human health and all regulations that rely on the Endangerment Finding, including the 2024 light-duty, medium-duty, and heavy-duty vehicle emissions standards regulations that provided the foundation for the Biden-Harris electric vehicle mandate.
• Additionally, EPA plans to consider rescinding its Endangerment Finding for greenhouse gas (GHG) emissions from aircraft, with a proposed rule expected by the end of 2025.

Every stakeholder with an interest in these regulatory actions should consider how these changes will impact their interests and operations, as well as the future of the regulatory landscape, and consider engaging in the upcoming public comment periods.

For assistance with government relations or environmental matters, please contact CMBG3 Law and our environmental team. Our team is ready to provide guidance on regulatory issues, policy changes, and compliance concerns.