PFAS Regulations in 2025: What Florida Developers and Landowners Need to Know
If you own, develop, or manage property in Florida, keeping up with PFAS regulations has never been more critical.
Known as “forever chemicals,” PFAS compounds are under increasing scrutiny from the EPA and Florida regulators. However, 2025 has brought new uncertainty: while some rules are being challenged, liability for PFAS contamination remains — and it could impact your property.
At Creative Environmental Solutions (CES), we help developers, municipalities, and landowners navigate this evolving regulatory landscape. Here’s what you need to know about the latest EPA PFAS regulations and how they may impact projects in Florida.
Regulatory Uncertainty Is Growing
In January 2025, the Midnight Rules Relief Act opened the door to reversing several high-profile PFAS rules implemented during the Biden administration.
The first-ever national drinking water maximum contaminant levels (MCLs) for PFAS
Lead and Copper Rule improvements, which intersect with PFAS-related water infrastructure
What this means: Even if some rules are rolled back, PFAS liability under federal and Florida PFAS regulations isn’t going away. Developers and landowners must continue to account for PFAS risks during due diligence, property transactions, and site remediation.
CERCLA Designations Are Active — Even If Challenged
In April 2024, PFOA and PFOS were officially designated as hazardous substances under CERCLA (Superfund). This designation allows:
Cost recovery actions for cleanups
Reopening of previously closed cleanup sites
Retroactive liability for “passive receivers” such as landfills and wastewater treatment plants
Even if legal challenges delay enforcement, this designation places property owners, municipalities, and even solid waste facilities at risk of liability related to PFAS. For developers and landowners, understanding a property’s PFAS exposure is essential to avoid costly surprises.
Legal Challenges to EPA’s PFAS Standards
In early 2025, petitions (Case No. 24-1188) were filed challenging the EPA’s PFAS regulations related to drinking water standards. Opponents argue that the EPA:
Grouped PFAS chemicals together unfairly
Overlooked some of the economic impacts of compliance
While these legal battles may delay the full implementation of the drinking water rules, the pressure remains on municipalities and utilities to address PFAS contamination — a cost that may ultimately impact property owners and developers who rely on those systems.
Landfills and Wastewater Facilities Are on the Frontlines
EPA testing methods for PFAS (Methods 1621 and 1633) now allow for validated detection of 40 PFAS compounds. This creates new challenges for landfills and wastewater facilities:
Facilities accepting PFAS-containing waste (even passively) may face new remediation liabilities.
Treatment costs are rising sharply as stricter testing exposes more contamination.
Public entities and solid waste operators are struggling to prepare for enforcement.
For developers working near landfills or wastewater plants — or considering redeveloping former disposal sites — proactive PFAS testing and risk assessment are critical.
Expanded Reporting Requirements for PFAS
Under TSCA Section 8(a)(7), PFAS manufacturers and importers must now report uses, exposure data, and production volumes dating back to 2011.
Additionally, the Toxics Release Inventory (TRI) has expanded its PFAS reporting, eliminating exemptions that previously shielded some smaller releases.
For businesses involved in manufacturing, importing, or indirectly handling PFAS-containing materials, this means increased oversight and reporting obligations — and higher risks of noncompliance.
What Developers and Landowners Should Do Next
Even with ongoing challenges to federal rules, EPA regulations on PFAS are reshaping how properties are assessed, purchased, and redeveloped. Florida landowners and developers should:
Partner with CES for PFAS Compliance and Risk Management
At Creative Environmental Solutions, we help Florida property owners, developers, and municipalities navigate the complex regulations surrounding PFAS — from site assessments and permitting to remediation and regulatory coordination.
Contact us today to discuss your project and learn how we can help you stay compliant and protect your investment.
