November 2025 PFAS Legislative Developments

(November 1 – November 30)

Current Trends in Legislation – November 2025

Federal Legislature

  • No new bills were introduced.

Federal Regulations

  • 90 FR 50923 was submitted as a proposed rule on 11/13/2025. The EPA proposes to incorporate certain exemptions and other modifications to the scope of the reporting regulation set by the Toxic Substances Control Act 40 CFR 705. Exemptions would remove some reporting on activities about which manufacturers are least likely to know or reasonably ascertain. One such exemption proposes a de minimis concentration exemption for reportable PFAS in mixtures or articles under which PFAS concentrations below 0.1%.

    State Legislature

    • Five new bills were introduced.

    State Regulations

    New Bills This Period

    PFAS Legislation

    Federal

    • No new bills introduced.

      State

      • One bill introduced in MA.
      • Two bills introduced in NJ.
      • Two bills introduced in WI.

        Signed into Law

        Highlighted Regulations – PFAS Legislation

        Federal
        State
        State Bill: AB635 (WI)
        • Bill Title: An Act notifying counties and tribes of an exceedance of groundwater protection standards or standards for PFAS
        • Sponsor:Representative Billings
        • Introduced: 11/7/2025
        • Summary: This bill creates a statutory requirement for the Department of Natural Resources to notify county health departments, tribal health departments, and county land and conservation departments when groundwater protection standards or PFAS standards are exceeded.
        • Notes: SB628 was introduced as an identical bill in the state senate.
        State Bill: A6014 (NJ)
        • Bill Title: AN ACT concerning funding for the remediation of PFAS
        • Sponsor:Robert Auth
        • Introduced: 11/17/2025
        • Summary: The bill establishes an interest-bearing escrow account known as the PFAS Settlement Remediation Fund, which will be administered by the Department of Environmental Protection and funded by settlements with 3M Company related to PFAS contamination. Funds are designated exclusively for purchasing filtration systems, filter replacements, or other equipment to remove PFAS from drinking water or remediate contamination, as well as to reimburse local government units for similar equipment purchases.
        State Bill: S4798 (NJ)
        • Bill Title: AN ACT concerning PFAS in apparel
        • Sponsor:Linda Greenstein
        • Introduced: 11/6/2025
        • Summary: The bill proposes to ban the sale, manufacture, and distribution of apparel with intentionally added PFAS beginning two years after the law takes effect.
        State Bill: SB2660 (MA)
        • Bill Title: An Act relative to toxic free kids
        • Sponsor:Joint Committee on Consumer Protection and Professional Licensure
        • Introduced: 11/10/2025
        • Summary: The bill proposes a comprehensive system to address toxic chemicals in children’s products by defining key terms such as ‘children’s product’ and ‘toxic chemicals.’ It requires manufacturers to report the use of certain chemicals, especially high priority ones, and mandates the creation of public lists of chemicals of concern and high priority chemicals. Specific to PFAS, the bill states that no manufacturer, wholesaler or retailer shall knowingly sell, offer for sale or distribute for use a children’s product or product component containing intentionally added PFAS.

        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.

        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.

        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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