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White House Releases Spring 2025 Unified Agenda  

Date: September 16, 2025

The U.S. Office of Information and Regulatory Affairs recently released the Spring 2025 Unified Agenda, with several U.S. Environmental Protection Agency (EPA) rulemakings that will impact WateReuse Association members.   

Several of the updates included in the Spring 2025 Unified Agenda focus on PFAS regulations. These actions were outlined across three offices of EPA including the Office of Land and Emergency Management (OLEM), Office of Chemical Safety and Pollution Prevention (OCSPP), and the Office of Water (OW). 

The Environmental Protection Agency will be rolling back PFAS regulations in drinking water for PFHxS, PFBS, Genx, PFNA, and mixtures of these PFAS as outlined in the National Primary Drinking Water Regulation from the April 2024 Final Rule. It is expected that we will see a Notice of Proposed Rulemaking (NPRM) on this sometime this month and a final action by February of next year. Similarly, EPA will be extending the deadline for compliance to meet the maximum contaminant level for PFOA and PFOS. This will also see an NPRM posted late this year and final action in April 2026.  

In 2024, OLEM released a proposed rule under the Resource Conservation and Recovery Act (RCRA) with a set of nine different PFAS that were to be added to the Hazardous Constituents list. This Final Rule is expected to be released in April 2026. Updates to these lists may indicate broader trends for which substances may see more regulatory compliance measures going forward., thus may impact what needs to be tracked and treated by utilities. Under OCSPP, the WateReuse Association tracks updates to the Toxic Substances Control Act and the Toxics Release Inventory, through which EPA assesses, monitors, and regulates new and existing industrial chemicals. See the details of these updates below.  

The WateReuse Association will continue to advocate that PFAS be regulated more stringently at the source, that utilities have the resources they need to help address PFAS contamination, and that polluters rather than utilities and taxpayers carry the financial burden of mitigating PFAS pollutionWaters of the U.S.  

The Unified Agenda for Spring 2025 also indicates that there will be updates made to the definition of “Waters of the United States,” or, WOTUS. The definition of WOTUS has changed over multiple administrations over multiple decades as decision makers seek to narrow or expand its scope. The updated final action is expected to be published in January 2026.  

According to Greenwire, these updates are likely to narrow protection of wetlands. Only wetlands that are directly connected to or adjacent to a surface water body or contain surface water throughout the “wet season” will be regulated. This proposed rule is called Clarifying the Legal Extent of Agency Regulation of Waters of the United States (CLEAR WOTUS) and is expected to be published as a final action by the end of this year.   

There are several other water reuse-related updates to the Unified Agenda that WateReuse will be tracking including those surrounding National Pollutant Discharge Elimination System (NPDES), Unregulated Contaminant Monitoring Rule 6 (UCMR6), and other effluent limitation guideline adjustments.  

Below are the listed regulatory actions that the WateReuse Association will be tracking and assessing going forward, as these are the most relevant to the work of the Association and its members. 

More Detail 

Learn more about the specific changes proposed in the Unified Agenda: 

PFAS 

Office of Land and Emergency Management 

Listing of Specific PFAS as Hazardous Constituents OLEM  

  • Final Rule expected April 2026, NPRM was in Feb 2024 
  • “Adding nine specific per-and polyfluoroalkyl substances (PFAS), their salts, and their structural isomers, to its list of hazardous constituents in 40 CFR part 261 Appendix V” 

Office of Chemical Safety and Pollution Prevention  

Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping under the Toxic Substances Control Act (TSCA); Revision to Regulation OCSPP 

  • Expected Final Rule June 2026, NPRM December 2025  
  • “As promulgated in October 2023, the regulation requires manufacturers (including importers) of PFAS in any year between 2011-2022 to report certain data to EPA related to exposure and environmental and health effects. EPA plans to propose the incorporation of certain exemptions and other modifications to the scope of the reporting rule.” 

Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Change of Submission OCSPP 

  • “The Environmental Protection Agency (EPA or Agency) is amending the data submission period for the Toxic Substances Control Act (TSCA) PFAS reporting rule by changing the start date for submissions and making corresponding changes to the end dates for the submission period, i.e., the data submission period begins on April 13, 2026, and ends on October 13, 2026, with an alternate end date for small manufacturers reporting exclusively as article importers of April 13, 2027” 
  • Currently in effect 

Addition of Certain Per- and Polyfluoroalkyl Substances (PFAS) to the Toxics Release Inventory (TRI)  

  • Final Rule Expected February 2026  
  • “The Environmental Protection Agency (EPA) is developing a final action to add individually listed per- and polyfluoroalkyl substances (PFAS) and PFAS categories to the Toxics Release Inventory (TRI) list of toxic chemicals subject to reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA) and the Pollution Prevention Act (PPA). EPA is evaluating comments received on the proposed rule published on October 4, 2024 and will consider how to address PFAS compound categories and what events may trigger the automatic addition of a PFAS to the TRI.” 

Office of Water 

Extending the Compliance Deadline for the PFAS National Primary Drinking Water Regulation Rulemaking  

  • Expected Final Action April 2026, NPRM October 2025  
  • Proposing new rule to extend the deadline for compliance to utilities for MCLS for PFOA and PFOS 

Withdrawal of Regulatory Determinations and removal of Related Provisions for Four PFAS Substances (PFHxS, PFNA, HFPO-DA (GenX), and the mixture of these three PFAS plus PFBS) 

  • Expected Final Action February 2026, NPRM September 2025 
  • EPA rescinding PFAS regulations associated with April 2024 rule on PFHxS, GenX, PFNA, PFBS 

Clean Water Act Effluent Limitations Guidelines and Standards for PFAS Manufacturers Under the Organic Chemicals, Plastics and Synthetic Fibers Point Source Category  

  • Expected January 2026 
  • “…initiating further data collection and analysis to support potential future rulemaking, under the Clean Water Act (CWA), relating to the effluent limitations guidelines, pretreatment standards and new source performance standards applicable to the Organic Chemicals, Plastics and Synthetic Fibers (OCPSF) point source category to address discharges from manufacturers of per- and polyfluoroalkyl substances (PFAS) and is considering revising the same for formulators of PFAS…”  

Waters of the US 

Final Clarifying Definition of “Waters of the United States”  

  • Expected Final Action January 2026  

NPDES 

PFAS Requirements in NPDES Permit Applications  

  • Expected as Final Rule in May 2027, NPRM in November 2025  
  • “This proposed rulemaking seeks to update requirements for several of the existing NPDES permit applications to address monitoring and reporting of PFAS” 

Minor Corrections to National Pollutant Discharge Elimination System (NPDES) Regulations   

  • Direct Final Rule Expected August 2025 
  • Correct language in permitting  

Other Water Reuse Related Updates  

Effluent Limitations Guidelines and Standards for the Oil and Gas Extraction Category (40 CFR 435 Subpart E)  

  • Expected as Final Rule April 2026, NPRM October 2025  
  • “The rulemaking would evaluate increased opportunities for discharge of treated produced water by expanding the geographic area where such discharges can occur and evaluate increased opportunities to discharge for other uses (such as critical minerals extraction and industrial cooling water).” 

Revisions to Establish the Sixth Unregulated Contaminant Monitoring Rule (UCMR 6) for Public Water Systems  

  • Expected Final action December 2026, NPRM November 2025  
  • Preparing for 6th cycle of the UCMR to cover between 2027 – 2031 as statutory requirement under SDWA 

Clean Water Act Methods Update Rule 22 for the Analysis of Contaminants in Effluent 

  • Final Rule Expected March 2026  
  • Updating monitoring methods  

Water System Restructuring Assessment Rule  

  • Final Rule Expected November 2025 
  • Mandatory assessment of public water systems to determine compliance, if not in compliance must be under America’s Water Infrastructure Act and can apply into DWSRF to help fund restructuring planning.
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