August 2025 PFAS Legislative Developments

August Legislation Tracking (August 1 – August 31)

Current Trends in Legislation – August 2025

Federal Legislature

    • No new bills were introduced.

    Federal Regulations

    • There was a new pre-rule introduced regarding PFAS reporting per Toxic Substances Control Act. This will be a revision to the existing regulation per 40 CFR 705. Source documents are not available at this time, but EPA plans to propose the incorporation of certain exemptions and other modifications to the scope of the reporting rule.

State Legislature

  • Three bills were introduced across three states.
  • Topics include: PFAS in firefighting equipment; PFAS in agricultural equipment; PFAS in children’s products.

State Regulations

  • There were no state regulations to report.

New Bills This Period

PFAS Legislation

Federal

  • No new bills introduced.

    State

      • Three bills introduced.
      • One in MA
      • One in PA
      • One in TX

      Signed into Law

      •HB2409 (IL) was signed into law 8/15/25. This amends the Illinois Environmental Protection Act and provides that beginning 1/1/2026, an entity, including an importer or domestic distributor of firefighting personal protective clothing containing intentionally added PFAS chemicals, shall provide written notice to the purchaser at the time of sale which shall state: (i) that the fire protective clothing contains PFAS chemicals; and (ii) the reason PFAS chemicals are added to the clothing. The bill prohibits a person that sells auxiliary firefighting personal protective equipment to any person, local government, or State agency from knowingly manufacture, sell, offer for sale, distribute for sale or distribute
      •HB2516 (IL) was signed into law 8/15/25: This is a comprehensive PFAS ban.

          Highlighted Bills – PFAS Legislation

          Federal
          State
          State Bill: HB 4357 (MA)
          • Bill Name: An Act relative to toxic free kids 
          • Sponsors: Joint Committee on Consumer Protection and Professional Licensure
          • Introduced: 8/7/2025
          • Status: Introduced
          • Summary: This bill requires the creation of lists of toxic chemicals of concern and high-priority chemicals in children’s products, with specific requirements for manufacturers to notify the department of chemical use, especially for PFAS and other hazardous substances. It establishes a process for evaluating safer alternatives and requires manufacturers to either remove or substitute high-priority chemicals, with stricter restrictions on products that foreseeably will be near children’s mouths or marketed to children under three.
          State Bill: SB 980 (PA)
          • Bill Name: An Act Amending Title 35  
          • Sponsors: Gene Yaw
          • Introduced: 8/25/2025
          • Status: Introduced
          • Summary: The bill prohibits manufacturers from producing or selling class B firefighting foam with intentionally added PFAS chemicals beginning 7/1/2026 and bans their use in firefighting activities starting 1/1/2027, with exceptions for federally required uses and exempt facilities.
          State Bill: HB 290 (TX)
          • Bill Name: An Act relating to the production, sale, and use of certain agricultural products 
          • Sponsors: Representative Kerwin
          • Introduced: 8/22/2025
          • Status: Introduced
          • Summary: This bill prohibits the manufacture, sale, distribution, or application of certain agricultural materials containing PFAS above specified concentration thresholds in counties with populations between 175,000 and 195,000. Manufacturers in such counties must submit monthly samples to the Texas A&M AgriLife Extension Service for PFAS testing, and batches exceeding limits must be disposed of through hazardous waste methods. The bill also designates a Class A misdemeanor for violating these limits, which becomes a state jail felony if the offender has prior convictions under the same law.

          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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