Attorney General Bonta Joins Multistate Letter Opposing EPA’s Proposal to Weaken PFAS Reporting

OAKLAND - California Attorney General Rob Bonta today joined a multistate comment letter in opposition to the U.S. Environmental Protection Agency's (EPA) proposal to weaken reporting requirements under the Toxic Substances Control Act (TSCA) for per-and polyfluoroalkyl substances (PFAS), also known as "forever chemicals," enacted during the Biden administration. If implemented, this proposal would diminish a valuable source of information that could aid in identifying the sources, extent, and causes of PFAS contamination. In the comment letter, the attorneys general explain that the Trump Administration's illegal proposed exemptions would gut the reporting rule and hinder EPA's duty under TSCA to ensure PFAS do not present an unreasonable risk of injury to public health or the environment. The attorneys general also highlight that the proposal poses significant health risks by diminishing EPA's ability to identify and address toxic chemicals that threaten human safety and well-being, particularly for children, workers, and vulnerable communities.

"With this illegal proposal, the Trump Administration's EPA is choosing to put industry convenience over public health by ignoring the harms that toxic PFAS chemicals may pose," said Attorney General Bonta. "American workers and communities deserve to know about the chemicals they're being exposed to."

PFAS are a class of chemicals that have waterproof, non-stick, and stain-resistant properties. They have been used in many consumer and industrial products, including food packaging, non-stick cookware, clothing, carpets, paints, cleaning products, electric vehicle batteries, microchips, renewable energy machinery, and firefighting foam. Studies have thus far linked PFAS to numerous adverse health effects, such as cancer (including breast and testicular cancer), developmental delays, infertility, lower bone density, immune system damage, endocrine system harms, liver disease, heart disease, and high cholesterol. PFAS are long-lasting and highly mobile, and they have contaminated many waters and soils, particularly in and around airports, military facilities, PFAS manufacturing plants, landfills, and agricultural lands. This environmental contamination increases the risk of exposure to PFAS, especially through drinking water supplies. PFAS contamination is so widespread and costly to remediate that consultants estimate compensable injuries for natural resource damages alone at between $14 and $33 billion in California.

Enacted in 1976, TSCA gives the EPA the authority to regulate chemical substances to protect human health and the environment and to require manufacturers and importers to provide information on chemical substances. TSCA allows the EPA to evaluate existing and new chemicals for safety and empowers the EPA to restrict or ban chemicals that pose significant risks. In 2019, Congress enacted the National Defense Authorization Act for Fiscal Year 2020, which amended TSCA by adding a new provision that required EPA to issue a rule requiring PFAS manufacturers to report certain information to EPA. The Biden Administration's EPA issued such a rule in 2023 requiring any entity that manufactured PFAS compounds between January 1, 2011, and December 31, 2022, to report information to the EPA about that substance and how it was produced, used (including uses in commercial and consumer products), and disposed of. Importantly, this information could contribute to the development of TSCA regulations to protect human health and the environment from PFAS exposure; provide state legislatures and regulatory agencies with a more complete picture of PFAS usage and risks as they develop their own regulations; assist state and local governments (including public water and wastewater systems) in tracing, abating, and remediating PFAS contamination; and assist these governments in identifying and holding responsible the entities that caused contamination.

On November 13, 2025, the Trump Administration's EPA proposed a rule that would create exemptions to Biden Era EPA 2023 rule ("2025 Proposal"). The Trump Administration's 2025 Proposal would create exemptions to the reporting requirements and greatly reduce the ability to identify and address health risks to Americans.

In the comment letter, the multistate coalition explains that:

• The 2025 Proposal would gut the reporting rule by adding inappropriate exemptions that effectively would reduce the number of responding entities by over 98 percent, which will impede important data collection.
• EPA fails to provide a reasoned explanation for its sudden reversal and ignores scientific research showing the importance of collecting this data and EPA's prior detailed analysis as to why those same exemptions were not included in the 2023 rule.
• The proposed changes would ultimately result in additional harm to public health and the environment by depriving EPA and stakeholders of information about the chemical compositions and uses of specific PFAS chemicals. This lack of information could disproportionally endanger workers and vulnerable communities.
• The 2025 Proposal is unlawful. The comment strongly urges the EPA to fulfill its congressional mandate under TSCA by continuing to require robust reporting of vital information about PFAS.

Attorney General Bonta is a national leader in the fight to protect against the harms of PFAS contamination. He is prosecuting claims against major PFAS manufacturers such as 3M, DuPont, Chemours, and Corteva, and successfully co-led multistate coalitions in advocating for improvements to proposed class action settlements between public water systems and 3M and DuPont. That work can be found here, here, and here. Separately, he has supported stronger federal PFAS regulations under the Safe Drinking Water Act and the Resource Conservation and Recovery Act, and has taken measures to protect Californians from exposures to PFAS through food packaging and cookware.

In filing the comment letter, Attorney General Bonta is joined by the attorneys general of Connecticut, Hawaii, Illinois, Maryland Massachusetts, Michigan, Minnesota, New Jersey, New York, North Carolina, Oregon, Rhode Island, Washington and Wisconsin.