September and October 2025 PFAS Legislative Developments

(September 1 – October 31)

Current Trends in Legislation – September and October 2025

Federal Legislature

      • One new bill was introduced.

State Legislature

  • There were no new bills introduced.
  • Three bills were signed into law.

State Regulations

  • Multiple regulations were enacted as final rules.

New Bills This Period

PFAS Legislation

Federal

  • No new bills introduced.

    State

      • No new bills introduced.

      Signed into Law

    • CA bill AB60 was chaptered on 10/7/25. The bill prohibits the manufacture and sale of any cosmetic product that contains intentionally added PFAS.
    • CA AB1181 was chaptered on 10/6/25. The bill requires the Occupational Safety and Health Standards Board to modify its existing safety order for firefighter personal protective equipment by January 1, 2027, to eliminate performance standards that lead to the use of PFAS and other hazardous chemicals.
    • DE bill SB72 was signed by the governor 9/19/25. The bill requires the Division of Public Health to create a public website displaying PFAS levels in all public drinking water systems, including MCL thresholds for substances like PFOA, PFOS, and PFHxS. If PFAS levels exceed the established MCL, the water utility must notify affected residents via mail, including a detailed brochure explaining PFAS and the detected levels.

      • Highlighted Regulations – PFAS Legislation

      Federal
      Federal Bill: HR 5571
      • Bill Name: An Act to Amend the Social Security Act 
      • Sponsors: Representative Debbie Dingel
      • Introduced: 9/26/2025
      • Status: Referred to the Committee on Energy and Commerce
      • Summary: The bill proposes to amend the Social Security Act to include coverage for PFAS testing under Medicare.
      State
      State Regulation: 340-122-0115 (OR)
      • Final Rule Date: 9/12/2025
      • Summary: This regulation updates the definition of “hazardous substance” to include six PFAS.
      State Regulation: 15A NCAC 18C.1540 (NC)
      • Final Rule Date: 10/1/2025
      • Summary: This regulation formally incorporates the provisions of 40 C.F.R. 141, Subpart Z into state code.
      State Regulation: 06-096 Ch. 90 (ME)
      • Final Rule Date: 10/7/2025
      • Summary: This rule requires the establishment of designations for currently unavoidable uses of intentionally added PFAS in products subject to sales prohibition beginning January 1, 2026.
      State Regulation: 5 CCR 1002-11 (CO)
      • Final Rule Date: 9/10/2025
      • Summary: The regulation incorporates the EPA’s promulgation of Subpart Z and related revisions to the National Primary Drinking Water Regulations at 40 CFR Part 141 into its regulations on drinking water.
      State Regulation: R18-4-301 (AZ)
      • Final Rule Date: 10/31/2025
      • Summary: As it relates to PFAS, the regulation requires monitoring for PFAS in drinking water. Specifically, Monitoring Assistance Program (MAP) will conduct baseline PFAS sampling, including initial, routine, and reduced monitoring. The Department is in the process of analyzing what would be considered routine monitoring under the new PFAS rule.

      Updates on Previously Highlighted Bills

      Federal
      State
      HB1153 (MD) was approved by the Governor 5/9/2024. This bill establishes limits for PFAS in any water discharged by industrial entities.
      S25 (VT) was approved by the Governor 5/30/2024. This bill prohibits the sale of certain products, including cosmetics, mistral products, and textiles containing intentionally-added PFAS.

      John Gardella

      Shareholder

      PFAS, Environmental, Litigation

      John Gardella and his team were recognized by National Law Review as the only Thought Leader in the nation in 2020 on the subject of PFAS. Attorney Gardella regularly consults with corporate, insurance, and financial world clients to assess risks in a multitude of transaction types. While he has specialized his practice for the past five years on the subject of PFAS, he has fifteen years of litigation and environmental practice that shapes the expertise that he offers to his clients to predict future risks. His opinions are sought out by media, such as Bloomberg, AM Best, and numerous industry-specific publications.

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      Amaran Toppa

      Director of Client Relations & Development

      Amaran Toppa joined CMBG3 Law in 2017 after almost three years in the investment management industry. In addition to her time in the financial sector, Mrs. Toppa has over 15 years of experience working with law firms who have litigated and consulted on ESG, Environmental, Insurance, Toxic Tort, Criminal and Civil matters. As a member of the CMBG3’s Government Affairs team, Mrs. Toppa analyzes and provides guidance on important policy and regulatory issues to the firm’s practice groups. She also assists with strategizing policy responses and develops relationships with key federal and state legislators and agency members to lobby on issues important to the firm’s clients.

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      Tori Paiva

      Legislative Analyst

      Tori Paiva is a Legislative Analyst at CMBG3 Law specializing in ESG, PFAS, Environmental and Tort issues. Ms. Paiva has extensive knowledge and expertise pertaining to federal regulators bodies including OSHA, EPA, DEP, and the FDA. With her expertise on both federal and local regulations, she has helped with the national defense strategies for her clients and continues to inform our attorneys on pertinent issues developing in the regulatory realm. As a member of the Government Affairs team, she is responsible for monitoring and reporting on legislative priorities, and regularly attends congressional hearings. As a registered lobbyist, Ms. Paiva also meets with Federal and State stakeholders to advance priorities important to firm clients.

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