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2025 Analysis

Phasing out PFAS use

Insights and Predictions into 2025

Phasing out PFAS use

In recent years, the U.S. has seen a surge in policies to address PFAS—a class of chemicals known as “forever chemicals” because they do not break down in the environment. Over the last eight years, states have increasingly adopted policies restricting PFAS, and those actions—in conjunction with at least 30 percent of retailers recently evaluated committing to eliminating PFAS in key product sectors —have contributed to a reduction of PFAS in the marketplace. However, states recognize the ongoing need for action.

PFAS Uses and Health Concerns

PFAS (per- and polyfluoroalkyl substances) are a class of nearly 15,000 chemicals used to make products like cookware, food packaging, carpets, clothing, and firefighting foams. They are also used in industrial processes and are often discharged into waterways. 

Research has linked PFAS exposure to various health problems including weakened immune function, cancer, increased cholesterol levels, pregnancy-related hypertension, liver damage, reduced fertility, and thyroid disease. As evidence of how toxic these chemicals can be, in 2024 the Environmental Protection Agency (EPA) finalized drinking water standards for several PFAS chemicals at levels as low as 4 parts per trillion.  

Nearly all U.S. residents have PFAS in their bodies, with studies detecting these chemicals in blood, breast milk, umbilical cord blood, placenta, and other tissues.

Expected PFAS Policy and Regulations 

This year at least 29 states will likely consider policies to address the PFAS crisis, ranging from eliminating their use in products to limiting the spreading of PFAS-containing sludge on farmland and setting water standards. These states include Alaska, Arizona, California, Connecticut, Hawaii, Illinois, Indiana, Kentucky, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Montana, Nevada, New Jersey, New Mexico, New York, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Texas, Vermont, Virginia, and Washington. 

Map showing U.S. states anticipated to consider PFAS-related policy in 2025, highlighted in orange. Other states are shown in gray.

Prevention-based Policies

States have stepped up to address the PFAS contamination crisis with novel policies designed to tackle the root of the problem. These approaches include:

  • Setting bold goals to end the use of PFAS in products by specific dates.
  • Requiring transparency to ensure access to critical information.
  • Banning the entire class of PFAS to prevent the use of regrettable substitutes and eliminate unnecessary uses, such as in food packaging.
  • Identifying and investing in safer alternatives to help companies transition away from PFAS and other equally bad chemicals and materials.
  • Holding polluters financially accountable and providing resources to clean up contaminated communities.

Currently, 24 states have adopted a common, scientifically grounded definition of the class of PFAS. However, in 2024, some PFAS manufacturers and users attempted to weaken these protections by redefining PFAS in a way that would exclude certain widely used PFAS chemicals including plastic and gaseous forms. Chemical industry-backed efforts to weaken PFAS regulations are expected to persist in 2025.

 

Prevention-based policies under consideration in 2025
  • At least 16 states will likely consider phasing out all unnecessary uses of PFAS,  phasing out PFAS use in specific product categories; and/or requiring disclosure of PFAS in all products. These states include Alaska, California, Hawaii, Illinois, Massachusetts, Maryland, Michigan, Minnesota, Montana, New Mexico, Nevada, New Jersey, New York, Oregon, Pennsylvania, and Washington. 

These policies continue the trend of states aiming for broad PFAS product restrictions and are similar to broad policies adopted in Colorado, Connecticut, Maine, Minnesota, Rhode Island, Vermont, and Washington. Additionally, Washington is considering PFAS restrictions through rulemaking under its Safer Products for Washington law and is in the process of determining whether to prioritize PFAS in paint for potential regulatory action. 

Some of the product categories being prioritized by states include: cosmetics and personal care products, textiles, cleaning products, waxes and polishes, cookware, and artificial turf. These policies build on actions in other states over the last several years. 

  • At least 11 states will likely consider protections for firefighters and communities by restricting the use of PFAS in firefighting foam and/or personal protective equipment (PPE). States include: Alaska, Connecticut, Illinois, Maine, Montana, New Jersey, New York, Oregon, Pennsylvania, Rhode Island, and South Dakota. 

PFAS in firefighting foam is a leading source of drinking water contamination and while there has been significant progress to transition to safer foams, PFAS foams can still be used in many states, particularly at airports and other industrial facilities. 

At least seven states will consider policies to eliminate PFAS from firefighting foam, including phase-out, restrictions, and/or take-back programs: Connecticut, Maine, Montana, New Jersey, New York, Oregon, and Pennsylvania. Fifteen states have adopted phase-outs of PFAS in firefighting foams, and both the military and the Federal Aviation Administration (FAA) have been directed by Congress to stop using PFAS-based firefighting foams. However, there is no federal requirement for airports to end use of PFAS foams.

Firefighters and scientists are concerned about PFAS and other chemical exposures contributing to cancer—the leading cause of line-of-duty deaths for firefighters.  

At least six states will consider policies that phase out the use of PFAS or require disclosure of the presence of PFAS in Personal Protective Equipment (PPE) and/or create resources to pay for new gear once viable safer alternatives are available: Alaska, Illinois, Montana, New Jersey, Rhode Island, and South Dakota.

Pollution Management Policies

PFAS are being found in water systems around the country and states are at the forefront of researching the extent of the problem and then finding resources to manage the pollution.

More than 143 million Americans are estimated to be drinking PFAS-contaminated drinking water and an estimated $3.2 billion dollars in taxpayer money has been spent in states to clean up PFAS pollution. Additionally, sewage sludge, widely used as fertilizer and referred to as “biosolids” by industry, becomes heavily polluted with toxic chemicals, including PFAS.  The contaminated sludge pollutes the soil when applied to farmland and toxic chemicals can get transferred to our food.

A key element to the long-term strategy for a healthier world is identifying and managing sources of pollution and cleaning up existing contamination. With this goal in mind, states will likely consider policies that:

  • Require testing and monitoring of PFAS in water.
  • Set drinking water limits for PFAS.
  • Require testing of and restrict PFAS in sludge that can be applied to farmland and forests.
  • Designate resources for PFAS cleanup.
Pollution management policies under consideration in 2025
  • At least eight states will consider policies that require testing, monitoring, and/or disclosure of PFAS in water including Connecticut, Hawaii, Indiana, Maine, Massachusetts, New Jersey, New York, and Virginia. The true scope of PFAS and microplastic contamination is unknown since testing is still somewhat limited. Many states are working to increase testing in order to better understand the extent of their pollution problems. There is particular momentum to help people on well water systems test for and address PFAS contamination.
  • At least 12 states will consider solutions to the challenge of PFAS in sludge including Hawaii, Indiana, Maryland, Massachusetts, Maine, Michigan, Minnesota, Mississippi, Oklahoma, Oregon, Texas, and Washington. Because PFAS doesn’t break down and pollution sources are highly diffuse, the chemicals end up in the sludge/biosolids that are left over after water treatment. When this sludge is spread on farmland, it can contaminate the soil and impact the livelihoods of farmers. States are stepping up by requiring testing, labeling fertilizers made from sludge, and/or creating resources to support farmers who discover contamination.
  • At least seven states will consider policies to create standards for PFAS in drinking water, groundwater, and/or surface water and/or restrict PFAS in effluent including Alaska, California, Indiana, Maine, New York, South Carolina, and Virginia. Following state leadership, the federal government has finalized drinking water standards for six individual PFAS chemicals. States are continuing to act to protect communities and are considering setting standards and restrictions for PFAS in industrial use and emissions as well as groundwater and/or surface water since they are important sources of current and future drinking water for U.S. residents. Some states will consider policies to harmonize their drinking water standards with the federal standards adopted in 2024.
  • At least six states will consider policies or designate resources for PFAS cleanup including Connecticut, Massachusetts, Minnesota, New Jersey, Rhode Island, and Washington. Local jurisdictions are struggling to clean up widespread PFAS contamination and states are stepping up efforts to provide resources. To date, at least 30 state attorneys general have filed lawsuits against the manufacturers of PFAS to help clean up polluted water, air, and soil.

Table of Contents

  1. I.Introduction
  2. II.Methodology
  3. III.Phasing out PFAS use
  4. IV.Addressing harmful plastics and packaging
  5. V.Moving toward safer cosmetics and personal care products
  6. VI.Chemical disclosure and restrictions
  7. VII.Conclusion
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