Trump’s Withdrawal of Proposed PFAS Regulation Evidences Project 2025 Influence

Using similar language to Project 2025, Trump’s Day-One regulatory freeze rolls back regulation to PFAS discharge.

Written by Amanda Magnani                                                                         Published: 2/19/25

On his first day in office, President Trump effectively killed a proposal to limit the discharge of so-called “forever chemicals” into water sources. The executive order made good on a plan from the infamous Project 2025 roadmap.

Trump’s move to stop regulation of per- and polyfluoroalkyl substances (PFAS) was one of a slew of orders. It came as part of a regulatory freeze on all proposals pending White House review. The PFAS proposal was one of several removed from consideration. The move ran counter to his promise to deliver the “cleanest air and water.” PFAS are endocrine disruptors and are linked to serious health issues, such as cancer, immune suppression and miscarriage.

The proposal to limit PFAS in wastewater was heavily pushed by environmentalists under the Biden Administration and was awaiting the last step before being released for public comment. The draft rule was supposed to finish review while still under the prior administration, yet it remained on the federal docket for months and was ultimately pulled from the White House’s Office of Management and Budget’s websitefollowing Trump’s executive order.

Project 2025 is the product of the Heritage Foundation, one of the most influential right-wing think tanks in D.C. Heritage has long been aligned with fossil fuel and chemical interests, having received funding over the years from sources like billionaire Charles Koch, owner of Koch Industries. Increasingly, it has cozied up to Trump and MAGA. In 2022, Trump declared that the Heritage Foundation would “lay the groundwork” for his possible second mandate.

Still, on the campaign trail, the President sought to distance himself from the group’s roadmap, claiming he had “nothing to do with Project 2025,” and that he had no intention of purposely reading the document. But Project 2025’s influence on the regulatory freeze and on the PFAS proposal is not hard to see. Since taking office, Trump has closely followed Project 2025’s guidelines in his handling of the EPA.

The Heritage Foundation’s policy brief thrice mentions the need for a regulatory “pause and review” for the EPA—something it recommends be done through a “Day One Executive Order”—much like the one signed by President Trump. As Project 2025 notes, “the new President’s Inauguration Day regulatory review/freeze directives should avoid exceptions for EPA actions” and should “explicitly include quasi-regulatory actions, including assessments, determinations, standards, and guidance, that have failed to go through the notice-and-comment process and may date back years.”

While Project 2025 did not suggest the withdrawal of all rules not yet signed into law, it is not uncommon for incoming administrations to pause or throw out proposals pending review in the early days. However, Project 2025 does propose the removal of unfinalized rules regarding the Clean Air that have sat in the Federal Register for over one year.

Project 2025 mentions PFAS twice, noting a need to “revise groundwater cleanup regulations and policies to reflect the challenges of omnipresent contaminants like PFAS.” It also calls to “revisit the designation of PFAS chemicals as ‘hazardous substances’ under [the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA)].” Under the Biden administration, the EPA made the decision to give PFAS the CERCLA designation, allowing industry to be held financially responsible for cleaning up public water systems contaminated with the chemicals.

In April 2024, the same month it handed down its CERCLA designation, the EPA set a national maximum water contaminant level and gave facilities five years to implement solutions to reach new goals. The move followed research showing that no level of exposure to PFAS was safe for humans.

The EPA also drafted a separate proposal that would set a federal limit on the discharge of PFAS in water sources. Sent in June 2024 for mandatory review by the White House Office of Budget and Management, it was this proposal, which had not yet been approved, that was withdrawn by President Trump.

The 2024 legally enforceable standard, on the other hand, which has already been published, is harder for the current administration to roll back. The Clean Drinking Water Act has an “anti-backsliding provision…that prohibits rules from being weakened,” said Natural Resources Defense Council Senior Director for Health, Erik Olsen. Olsen doesn’t believe Trump’s new administration will be able to easily erode such legislation.

For activists and environmentalists, the action is seen as a “dangerous message giving polluters a green light to continue poisoning our water and communities without fear of consequence,” said Melanie Benesh, Vice President for Government Affairs at the Environmental Working Group. For Benesh, such a setback “delays establishing critical federal standards” and stalls actions at the state-wide level as well, since regulators wait to follow the federal government’s lead.

The withdrawal of the PFAS proposal appears to be only the beginning of a coming wave of environmental setbacks from the Trump Administration, following a Project 2025 playbook, the Heritage Foundation and chemical and fossil fuel lobbyists.

A spokesperson for the EPA noted that the agency under Trump “... was also the first to ever issue a comprehensive nationwide PFAS action plan.” It is unclear what plan the spokesperson was referencing.