April 2025 PFAS Legislative Developments

April Legislation Tracking (April 1 – April 30)

Current Trends in Legislation – April 2025

Federal Legislature

    • Two new bills were introduced, one of which seeks to prioritize the procurement of PFAS-free materials.

Federal Developments

    • The EPA Administrator, Lee Zeldin, publicized a press release that outlines upcoming agency action to address PFAS. Zeldin expressly mentioned the intent to protect passive receivers from liability.

State Legislature

  • Twenty three bills were introduced across twelve states.
  • Topics include: Water quality in relation to PFAS; PFAS in firefighting equipment; PFAS in cosmetics; comprehensive PFAS bans.

State Regulations

  • There were no significant developments in state regulations.

New Bills This Period

PFAS Legislation

Federal

  • Two new bills introduced.

    State

      • Twenty three bills introduced.
      • One in AL
      • One in CO
      • One in CT
      • One in GA
      • Five in ME
      • Two in MN
      • Two in MA
      • One in NJ
      • Two in NY
      • Three in NC
      • Three in PA
      • One in WA

      Signed into Law

      H.B 212 (NM) was signed into law on 4/8/2025. This bill is a comprehensive effort to ban PFAS, including prohibition of the use of PFAS in various products.

          Highlighted Bills – PFAS Legislation

          Federal
          Federal Bill: HR 3110
          • Bill Name: An act to prohibit the procurement of certain items and prioritize the procurement of products not containing PFAS 
          • Sponsors: Mike Lawler
          • Introduced: 4/30/2025
          • Status: Introduced
          • Summary: The bill text is not available as of 5/2/2025.
          State
          State Bill: HB 541 (AL)
          • Bill Name: Safe Drinking Water Act 
          • Sponsors: Rep. Rafferty
          • Introduced: 4/8/2025
          • Status: Introduced
          • Summary: This bill would require the department to investigate the presence of PFAS in public drinking water systems and drinking water sources, and determine the responsible parties. The bill seeks to limit the liability of certain entities for the release of PFAS. Specifically, the bill states an owner or operator of a public water treatment plant, water distribution system, wastewater treatment plant, or public wastewater collection system may not be held liable for a discharge containing PFAS that complies with a valid national pollutant discharge elimination system (NPDES) permit.
          State Bill: HP 1197 (ME)
          • Bill Name: An Act to Require the Department of Environmental Protection to Provide Certain Information  
          • Sponsors: Poppy Arford
          • Introduced: 4/24/2025
          • Status: Referred to Committee on Environment and Natural Resources
          • Summary: The bill requires the DEP to disclose the presence of PFAS in well water to affected owners.
          State Bill: SP 641 (ME)
          • Bill Name: An Act to Protect Groundwater and Surface Waters from PFAS from Landfill Leachate 
          • Sponsors: Michael Tipping
          • Introduced: 4/10/2025
          • Status: Referred to Committee on Environment and Natural Resources
          • Summary: The bill requires any entity that discharges wastewater to maintain a record of the discharge and to test, on a quarterly basis, any leachate for the presence of PFAS.
          State Bill: HB 686 (NC)
          • Bill Name: Safe Cosmetics Act 
          • Sponsors: Rep. Belk
          • Introduced: 4/1/2025
          • Status: Referred to the Committee on Rules
          • Summary: The bill seeks to prohibit the distribution of any cosmetic product that contains PFAS.
          State Bill: HB 881 (NC)
          • Bill Name: PFAS Free NC 
          • Sponsors: Rep. Harrison
          • Introduced: 4/9/2025
          • Status: Referred to the Committee on Rules
          • Summary: The bill is a comprehensive PFAS ban. Among other prohibitions, the bill prohibits the manufacture of PFAS for use within NC or for export. The bill also prohibits the use of any PFAS for the production of any product within the State, or for export, except for products specifically authorized or required to contain PFAS under federal law.
          State Bill: HB 882 (NC)
          • Bill Name: Break Free From Plastic & Forever Chemicals 
          • Sponsors: Rep. Harrison
          • Introduced: 4/9/2025
          • Status: Referred to the Committee on Rules
          • Summary: The bill seeks to prohibit the use of PFAS in the state, and to qualify liable for responsible parties. The bill stipulates the requirements of a stewardship program that is to be implemented by a “producer responsibility organization.”
          State Bill: A 7738 (NY)
          • Bill Name: AN ACT to amend the environmental conservation law 
          • Sponsors: Deborah Glick
          • Introduced: 4/8/2025
          • Status: Introduced
          • Summary: The bill prohibits the sale of certain consumer and household products that contain PFAS.
          State Bill: HB 1116 (PA)
          • Bill Name: PFAS Chemicals in Biosolids Act 
          • Sponsors: Rep. Pugh
          • Introduced: 4/3/2025
          • Status: Referred to Environment and Natural Resource Protection
          • Summary: The bill requires the DEP to conduct a comprehensive study on PFAS chemicals in biosolids that are authorized by the department for use in the state. Among the testing to be done, the DEP shall study the concentrations of PFAS chemicals in biosolids used for land application on farmland. The DEP is also to study the presence of PFAS in livestock and crops.

          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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