EPA's Spring 2025 regulatory agenda focuses on PFAS, fossil fuels, and rule reconsiderations

The Environmental Protection Agency (EPA) published the Spring 2025 Semiannual Agenda of Regulatory and Deregulatory Actions on September 4, 2025. The agenda outlines the agency’s upcoming regulatory actions and their status in the rulemaking process.

EPA has major updates on the docket, such as:

• Repealing all greenhouse gas (GHG) standards for fossil fuel-fired power plants and the 2024 amendments to the Mercury Air Toxics Standard for power plants (final rules expected December 2025);
• Establishing risk management rules for multiple chemical substances, such as 1-bromopropane and n-methylpyrrolidone (final rules expected April 2026);
• Adding hazardous waste solar panels to the federal universal waste program and setting universal waste standards specific to lithium batteries (proposed rule expected February 2026);
• Setting the Renewable Fuel Standards for 2026 and 2027 and implementing regulatory program changes (final rule expected October 2025); and
• Reconsidering current rules, like:
  • The GHG Reporting Program (final rule expected November 2025),
  • The National Emission Standards for Hazardous Air Pollutants (NESHAP) for iron and steel and the NESHAP for oil and natural gas (proposed rules expected November 2025 and December 2025, respectively), and
  • The 2024 amendments to the procedures for conducting Toxic Substances Control Act chemical risk evaluations (final rule expected April 2026).

Additionally, the agency intends to address per- and polyfluoroalkyl substances (PFAS) across multiple media. For example, EPA plans to:

• Rescind the National Primary Drinking Water Regulations for PFHxS, PFNA, GenX, and mixtures of these three as well as for PFBS (proposed rule expected September 2025);
• Add certain PFAS to the Toxics Release Inventory (final rule expected February 2026); and
• Address PFAS discharges from PFAS manufacturers (proposed rule expected January 2026).

This article highlights some of the major rules we’re monitoring closely. You can review the entire agenda to learn about all the rulemakings on EPA’s docket. Please note that the agenda dates are tentative, indicating when the agency seeks to publish the rulemakings in the Federal Register.

Final Rule Stage
Projected publication date	Title
December 2025	Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Under the Technology Transitions Provisions of the American Innovation and Manufacturing Act of 2020
January 2026	Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Common Sense Approach to Chemical Accident Prevention
February 2026	Addition of Certain Per- and Polyfluoroalkyl Substances (PFAS) to the Toxics Release Inventory (TRI)
February 2026	Initial Air Quality Designations for the 2024 Revised Primary Annual Fine Particle (PM2.5) National Ambient Air Quality Standards (NAAQS)
April 2026	Listing of Specific PFAS as Hazardous Constituents
Proposed Rule Stage
Projected publication date of notice of proposed rulemaking	Title
October 2025	Effluent Limitations Guidelines and Standards for the Oil and Gas Extraction Category (40 CFR 435 Subpart E)
October 2025	New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry
November 2025	Additional Reconsideration of Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review
November 2025	PFAS Requirements in NPDES Permit Applications
November 2025	Steam Electric Effluent Limitations Guideline Reconsideration Rule
December 2025	Updates to the RCRA Hazardous Waste Regulations and Related Technical Corrections — Permitting Updates Rule
January 2026	Paper Manifest Sunset Rule; Modification of the Hazardous Waste Manifest System
January 2026	Revision to “Begin Actual Construction” in the New Source Review Preconstruction Permitting Program
April 2026	Reconsideration of National Emission Standards for Hazardous Air Pollutants: Gasoline Distribution Technology Reviews and New Source Performance Standards Review for Bulk Gasoline Terminals
May 2026	Formaldehyde; Regulation Under the Toxic Substances Control Act (TSCA)
Pre-Rule Stage
Projected publication date or other action	Title
September 2025 (advanced notice of proposed rulemaking)	Visibility Protection: Regional Haze State Plan Requirements Rule Revision
December 2025 (end review)	National Emission Standards for Hazardous Air Pollutants for Brick and Structural Clay Products Manufacturing; and Clay Ceramics Manufacturing

Key to remember: EPA’s planned rulemakings may impact regulatory compliance with air, land, and water rules.