March 2025 PFAS Legislative Developments

March Legislation Tracking (March 1 – March 31)

Current Trends in Legislation – March 2025

Federal Legislature

    • One new bill was introduced.

State Legislature

  • Sixty six bills were introduced across fifteen states.
  • Topics include: Exemptions from PFAS bans; PFAS testing requirements; Establishing liability for PFAS contamination; Regulating PFAS contamination in water sources.

State Regulations

  • NH Env-Dw 1500 was published as a Final Rule. This is a rebate program for well water contaminated by PFAS. The purpose is to establish criteria and procedures for administering the PFAS removal rebate program for private wells.

New Bills This Period

PFAS Legislation

Federal

  • One new bill introduced.

    State

      • Sixty six bills introduced.
      • One in CT
      • One in DE
      • One in FL
      • Eight in HI
      • One in IA
      • Five in ME
      • Nine in MA
      • Eighteen in MN
      • One in NM
      • Two in NY
      • Eight in NC
      • Two in PA
      • Four in RI
      • One in TX
      • Four in WI

      Signed into Law

      No laws were signed in March.

          Highlighted Bills – PFAS Legislation

          Federal
          State
          State Bill: SB 1494 (CT)
          • Bill Name: An Act Concerning Testing for PFAS 
          • Sponsors: Environment Committee
          • Introduced: 3/6/2025
          • Status: Introduced
          • Summary: The bill requires water companies to test for PFAS levels and take remedial action when such tests reflect certain levels of PFAS. The bill states that if the average PFAS level for any water supply system, over a three-month period, exceeds twenty ppt, that water company must undertake one or more of the following measures: (1) Link the system to a different system that has PFAS levels below twenty ppt; (2) install a PFAS filtering system; or (3) blend well waters that have higher and lower levels.
          State Bill: SB 72 (DE)
          • Bill Name: An Act to Amend Title 16 of the Delaware Code  
          • Sponsors: Sen. Brown
          • Introduced: 3/13/2025
          • Status: Assigned to Health & Social Services Committee
          • Summary: The bill requires the Division of Public Health to publish, publicly online, the levels of PFAS in public drinking water systems. The bill also requires water utility companies to notify public water systems users if the PFAS in drinking water system exceeds the MCLs established in the bill.
          State Bill: HP 730 (ME)
          • Bill Name: An Act to Provide Water Service Infrastructure to Fairfield Residents 
          • Sponsors: Shelley Rudnicki
          • Introduced: 3/18/2025
          • Status: Introduced
          • Summary: The bill provides $10 million to the Kennebec Water District to expand water service infrastructure in Fairfield in response to PFAS contamination in private wells.
          State Bill: HP 861 (ME)
          • Bill Name: An Act to Protect the Drinking Water for Consumers 
          • Sponsors: Daniel Shagoury
          • Introduced: 3/27/2025
          • Status: Referred to the Committee on Health and Human Services
          • Summary: The bill establishes MCLs for certain PFAS and requires community water systems and non-transient, noncommunity water systems to conduct monitoring using standard analytical methods for the detectable level of PFAS established by EPA. The bill is to be effective beginning in 2026.
          State Bill: SP 419 (ME)
          • Bill Name: An Act Clarifying Exemptions from the Notification Requirements for Products Containing PFAS 
          • Sponsors: Bradlee Farrin
          • Introduced: 3/11/2025
          • Status: Introduced
          • Summary: The bill expands the list of vehicles and equipment exempt from the notification requirement that the products contain PFAS, including certain parts that are included in or as a component part of such products.
          State Bill: SF 2129 (MN)
          • Bill Name: Gross revenues tax on entities manufacturing and selling products containing PFAS 
          • Sponsors: Sen. Seeberger
          • Introduced: 3/3/2025
          • Status: Introduced
          • Summary: The bill proposes to impose a tax upon entities manufacturing PFAS. Specifically, the bill imposes a tax equal to 50% of gross revenue derived from products containing PFAS manufactured in Minnesota and sold to a distributor. For a retailer who has nexus in MN, a tax equal to 50% of gross revenue is imposed on revenue derived from the retail sale of products containing PFAS in Minnesota. Moneys collected from this tax are to be used to clean up PFAS contamination in the state.
          State Bill: H 569 (NC)
          • Bill Name: An Act to Protect the Citizens of North Carolina 
          • Sponsors: Rep. Davis
          • Introduced: 3/27/2025
          • Status: Introduced
          • Summary: The bill proposes that the Secretary may order a responsible party to pay a public water system any actual and necessary costs incurred by the public water system to remove, correct, or abate any adverse effects upon the water supply resulting from contamination for which the person is responsible. A responsible party shall be jointly and severally liable for all actual and necessary costs imposed by the Secretary. Nothing in this bill shall limit or diminish any rights of contribution for costs incurred. A public water system shall reimburse ratepayers of the system through a reduction in future rates charged if the public water system has previously expended funds to remove, correct, or abate any adverse effects upon its water supply resulting from PFAS contamination.
          State Bill: S 666 (NC)
          • Bill Name: 2025 Water Safety Act 
          • Sponsors: Sen. Lee
          • Introduced: 3/25/2025
          • Status: Referred to Committee on Rules and Operations
          • Summary: The bill proposes to fund support for mitigating the impacts of environmental contamination due to PFAS on local public water and wastewater systems.
          State Bill: S 645 (RI)
          • Bill Name: CONSUMER PFAS BAN ACT OF 2024 
          • Sponsors: Sen. DiPalma
          • Introduced: 3/7/2025
          • Status: Introduced
          • Summary: The bill amends the PFAS ban to exempt certain cookware that contains PFAS that are authorized by the FDA as safe for consumer contact.
          State Bill: HB 3738 (TX)
          • Bill Name: An Act relating to an annual study on PFAS in school lunches 
          • Sponsors: Rep. Shofner
          • Introduced: 3/4/2025
          • Status: Introduced
          • Summary: The bill provides that an annual study shall be conducted to determine levels of perfluoroalkyl and polyfluoroalkyl substances in food served to students under the school lunch program.
          State Bill: AB 130 (WI)
          • Bill Name: An act relating to exempting certain persons from PFAS enforcement actions under the spills law 
          • Sponsors: Rep. Mursau
          • Introduced: 3/13/2025
          • Status: Introduced
          • Summary: The bill exempts certain persons from PFAS enforcement actions under the Spills Law. The “spills law” stipulates that a person who possesses or controls a hazardous substance, or that causes the discharge of such hazardous substance, must notify the Department of Natural Resources immediately, restore the environment to the extent practicable, and minimize the harmful effects from the discharge. The bill exempts various entities including a person that owns, leases, manages, or contracts for property on which the PFAS contamination did not originate, unless the person also owns, leases, manages, or contracts for the property on which the PFAS discharge originated.

          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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