December 2025 PFAS Legislative Developments

December Legislation Tracking (December 1 – December 31)

Current Trends in Legislation – December 2025

Federal Legislature

    • Seven new bills were introduced.
    • Topics of note include PFAS in agriculture and a proposed federal cause of action for claims relating to PFAS exposure.

State Legislature

      • Sixteen bills were introduced across six states.
      • Topics included PFAS in packaging, comprehensive PFAS bans, and PFAS in agriculture.

    New Bills This Period

    PFAS Legislation

    Federal

    • Seven new bills introduced.

      State

        • Sixteen bills introduced.
        • Three in FL
        • Two in MA
        • Three in MO
        • Five in NH
        • One in NJ
        • Two in WI

        Signed into Law

        • NJ bill A 5537 passed in both houses; this bill relates to the use of PFAS in Class B firefighting foam.
        • NJ bill S 1042 passed in both houses; this is a comprehensive PFAS ban.

          Highlighted Bills – PFAS Legislation

          Federal
          Federal Bill: S 3353
          • Bill Name: Relief for Farmers Hit with PFAS Act 
          • Sponsors: Susan Collins
          • Introduced: 12/4/2025
          • Status: Referred to the Committee on Agriculture Nutrition and Forestry
          • Summary: The bill establishes a grant program to assist states, territories, and Indian tribes in addressing PFAS contamination on agricultural land. The program also includes educational initiatives, long-term data collection, and support for marketing efforts affected by public perception of PFAS contamination.
          • Note: Identical bill introduced in House, HR 6476.
          Federal Bill: S 3460
          • Bill Name: PFAS Accountability Act of 2025 
          • Sponsors: Kirsten Gillibrand
          • Introduced: 12/11/2025
          • Status: Referred to the Committee on Environment and Public Works
          • Summary: The bill creates a federal cause of action allowing individuals significantly exposed to PFAS to sue manufacturers who foresaw or should have foreseen human exposure. It establishes a medical monitoring remedy for those exposed, shifting the cost of monitoring to the responsible parties. The legislation does not preempt state claims or create an exclusive remedy, ensuring individuals can pursue both federal and state legal options.
          • Note: Identical bill introduced in House, HR 6626.
          Federal Bill: HR 6668
          • Bill Name: Clean Water Standards for PFAS Act of 2025 
          • Sponsors: Chris Pappas
          • Introduced: 12/11/2025
          • Status: Referred to the House Committee on Transportation and Infrastructure
          • Summary: The bill requires the Environmental Protection Agency to establish human health water quality criteria for measurable PFAS substances within three years of enactment. It sets specific deadlines for developing and finalizing effluent limitations guidelines for priority industries, with final rules required by September 30, 2028. The EPA must also implement monitoring requirements for discharges from various point sources and promulgate a standardized testing method for PFAS detection by January 31, 2026.
          Federal Bill: HR 6669
          • Bill Name: No Taxation on PFAS Remediation Act 
          • Sponsors: Chris Pappas
          • Introduced: 12/11/2025
          • Status: Referred to the House Committee on Ways and Means
          • Summary: The bill amends the Internal Revenue Code to exclude reimbursements for PFAS remediation from gross income for individuals. The legislation also extends the statute of limitations on credits or refunds related to the amendment, allowing claims to be filed within one year of the law’s enactment. The effectively removes a tax penalty from moneys used to remediate PFAS.
          State
          State Bill: HB 855 (FL)
          • Bill Name: Perfluoroalkyl and Polyfluoroalkyl Substances  
          • Sponsors: Rep. Long
          • Introduced: 12/19/2025
          • Status: Introduced
          • Summary: The bill establishes statewide cleanup target levels for PFAS and authorizes the Department of Environmental Protection to update these levels as needed. The legislation provides liability protection for bona fide prospective purchasers who conduct all appropriate inquiries and comply with ongoing obligations, with liability protection effective during the time they comply with the requirements. The bill also prohibits fire service providers from using PFAS-containing Class B firefighting foam after January 1, 2027, except in emergency operations or fire prevention services, and ensures eligibility for financial assistance for qualifying sites.
          State Bill: HB 4853 (MA)
          • Bill Name: An Act protecting our soil farms and food from PFAS contamination 
          • Sponsors: Joint Committee on Agriculture and Fisheries
          • Introduced: 12/31/2025
          • Status: Referred to the committee on House Ways and Means
          • Summary: The bill mandates a comprehensive study of sewage sludge disposal and PFAS contamination across Massachusetts, requiring the development of a statewide master plan by June 30, 2027. It establishes the Agricultural PFAS Relief Fund to assist farmers facing losses due to PFAS in soil, water, or livestock, and the Agricultural Fertilizer Purchasing Fund to help farmers offset increased fertilizer costs. It also provides immunity from liability for farmers harmed by PFAS from sources outside their control, while excluding those involved in PFAS production or disposal.
          • Note: Identical bill introduced in Senate, SB 2802.
          State Bill: HB 2400 (MO)
          • Bill Name: An Act Relating to Intentionally added PFAS 
          • Sponsors: Marty Joe Murray
          • Introduced: 12/12/2025
          • Status: Introduced
          • Summary: The bill establishes regulations on products containing intentionally added PFAS. It prohibits the sale of specific consumer products such as carpets, cleaning products, cookware, cosmetics, and juvenile products starting January 1, 2027, with exceptions for PFAS in internal components or electronic devices. Manufacturers must submit detailed information about PFAS content in their products, and violations are punishable by fines or imprisonment.
          State Bill: HB 1389 (NH)
          • Bill Name: An Act relative to PFAS facility liability 
          • Sponsors: Nancy Murphy
          • Introduced: 12/4/2025
          • Status: Introduced
          • Summary: This bill introduces strict liability for individuals or entities operating PFAS facilities where PFAS releases have led to groundwater contamination at or above 500 PPT, as defined by federal standards. It mandates compliance with federal regulations regarding the closure, removal, or decommissioning of equipment and structures involved in PFAS handling or storage
          State Bill: HB 1258 (NH)
          • Bill Name: An Act Relating to PFAS and Public Health Data 
          • Sponsors: Suzanne Vail
          • Introduced: 12/1/2025
          • Status: Introduced
          • Summary: The bill requires the Department of Environmental Services to publish all PFAS sampling and testing results, including from public water systems, private wells, surface and groundwater, biosolids, fish tissue studies, and air emissions, on a public website. The data must be updated every six months.
          State Bill: HB 1275 (NH)
          • Bill Name: An Act Relating to PFAS and Agriculture 
          • Sponsors: Wendy Thomas
          • Introduced: 12/1/2025
          • Status: Introduced
          • Summary: The bill establishes a dedicated agricultural PFAS relief fund to support farmers who have suffered losses or incurred costs due to PFAS in soil, water, or agricultural products from standard practices like sludge application. It grants civil immunity to farmers for damages arising from PFAS present in agricultural products due to standard practices. The fund will be financed through litigation recoveries, grants, federal reimbursements, and interest, and will be used for testing, water filtration, business adaptation, education, health assessments, and remediation.
          State Bill: HB 1789 (NH)
          • Bill Name: An Act Relative to Producer Responsibility 
          • Sponsors: Lucius Parshall
          • Introduced: 12/17/2025
          • Status: Introduced
          • Summary: The bill creates an extended producer responsibility program that mandates producers to register, pay fees based on packaging volume, and reduce packaging by specific weight targets over time, including an eventual prohibition on packaging that includes PFAS. Producers must also meet recycling goals and avoid using packaging with certain toxic substances. The Department of Environmental Services will oversee compliance, rulemaking, enforcement, and public outreach, while requiring annual reporting and a statewide assessment every five years.
          State Bill: AB 772 (WI)
          • Bill Name: An Act Relating to Packaging 
          • Sponsors: Rep. Snodgrass
          • Introduced: 12/17/2025
          • Status: Referred to Committee on Environment.
          • Summary: The bill creates a statewide packaging reduction and recycling program administered by the Department of Natural Resources through a nonprofit producer responsibility organization. The program includes prohibitions on certain toxic substances, including PFAS, in packaging and mandates fees based on packaging types to cover collection, transportation, and recycling costs.

          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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