EPA has developed Effluent Limitation Guidelines (ELGs) for 59 industrial categories but has finalized zero PFAS-specific discharge limits across them, according to a Congressional Research Service report updated Sept. 30. The 59-category framework, originally built under the Clean Water Act, covers everything from metal finishing to organic chemicals, plastics, and synthetic fibers — yet the agency's 2021 PFAS Strategic Roadmap timelines for 11 of those sectors have slipped repeatedly.

The report, authored by CRS specialist Laura Gatz, frames the gap as one of action, not authority. EPA has the legal power to regulate per- and polyfluoroalkyl substances (PFAS) in surface water and to designate them as toxic pollutants or hazardous substances, but it has done neither at the national level.

What rulemaking deadlines have already shifted?

Two ELG revisions anchor the current backlog. The proposed rule for the Organic Chemicals, Plastics, and Synthetic Fibers category appeared on the most recent Regulatory Agenda with a July target date, after EPA originally scheduled it for fall 2024. The Metal Finishing ELG proposal moved from spring 2026 to February 2027.

On the analytical side, EPA finalized Method 1633A in January 2024. The method tests for 40 PFAS compounds across eight environmental media, including biosolids and wastewater. EPA also finalized Method 1621, a nontargeted screen for thousands of known PFAS in water samples. A proposed rule to formally adopt both methods — what EPA described as "a necessary step for them to be nationally required for CWA use" — published in January 2025 but remains unfinalized.

Why does the biosolids track matter for circularity?

Biosolids — the treated solid residue from municipal wastewater treatment — sit at the heart of the circular economy argument for water utilities. Land-applied biosolids return nutrients to agricultural soils. PFAS contamination complicates that pathway.

EPA published a draft risk assessment for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) in biosolids in January 2025. Four months later, the agency issued draft guidance instead of finalizing the assessment, stating the draft had "a number of serious flaws." The June guidance recommends mitigation practices but imposes no binding national limits on land application, disposal, or incineration residues.

What funding is already in place?

The Infrastructure Investment and Jobs Act provided $1 billion over five fiscal years to address emerging contaminants, including PFAS, in wastewater through the Clean Water State Revolving Fund. That money flows to states regardless of whether EPA finalizes its federal standards.

What has EPA walked back?

In August, EPA rescinded its December 2022 state guidance on PFAS permitting, citing inconsistent application and confusion among states and permittees. The withdrawal leaves permitting authorities without federal direction on how to handle PFAS in discharge permits while ELG revisions remain pending.

Human health criteria for PFOA, PFOS, and perfluorobutane sulfonic acid (PFBS) sit in the same unfinished column. EPA published draft criteria for public comment in December 2024 but has not finalized them. Aquatic life criteria for PFOA and PFOS did finalize in October 2024, leaving states and tribal governments to draft their own water quality standards without final federal human health benchmarks.

What decides what happens next?

Members of the 119th Congress have introduced PFAS-related bills addressing surface water. The CRS report identifies funding, statutory deadlines, and congressional requirements as the levers that could compress the rulemaking timeline. The next milestone on the calendar is the July target for the Organic Chemicals, Plastics, and Synthetic Fibers ELG proposal, followed by the February 2027 Metal Finishing rule.