Trends 2026: Moving Past PFAS

2026 could see the United States entering a strange period for the regulation of per- and polyfluoroalkyl substances (PFAS). With a midterm election coming in November 2026 and the administration of President Donald Trump signaling a continued preference for deregulation, the policy landscape is increasingly being shaped by statehouses and courtrooms rather than the White House. At the same time, the Make America Healthy Again (MAHA) movement has muddied the waters, shaping federal attention on food-related PFAS exposures even as other federal regulatory efforts stall.

Meanwhile, businesses, regulators, and advocacy groups are facing growing pressure to reduce or eliminate PFAS use altogether. State-level actions have accelerated, creating a patchwork system of bans, reporting rules, and product restrictions that companies must contend with, even as some industries find ways to avoid regulation. On top of these challenges, there are key judicial decisions expected in 2026 that could redefine the boundaries of PFAS liability, disclosure obligations, and chemical oversight under the Toxic Substances Control Act (TSCA) and other statutes.