prodchem
Jul 8, 2026
The EPA's virtual public hearing on its proposed PFAS drinking water rules has now concluded, shifting attention to the next and more consequential stage of the rulemaking process. While the hearing allowed stakeholders to present oral statements, the written comment period remains open until July 20, 2026. Under the federal rulemaking process, detailed written submissions become part of the administrative record that the EPA reviews when developing a final rule.
For procurement professionals responsible for PFAS-containing products or supply chains, the remaining days before the deadline provide an opportunity to submit practical technical, commercial and scientific information that may help inform the agency's evaluation.
Public hearings provide transparency by allowing stakeholders to explain their views in an open forum. However, hearing statements are usually limited in time and cannot include the detailed evidence often needed for complex regulatory decisions.
Written comments allow organizations to present comprehensive information, including technical reports, cost analyses, operational experience and scientific references. These submissions remain part of the official rulemaking docket and can be reviewed throughout the EPA's evaluation process.
For many companies, a well-prepared written submission represents the most meaningful form of regulatory participation.
Before drafting comments, procurement teams should determine whether the proposed rule could affect their products, suppliers or customers.
Questions to consider include:
Do any purchased raw materials or finished products depend on the PFAS categories covered by the proposal?
Would changes in regulation affect product availability or supplier capacity?
Could alternative materials meet existing technical performance requirements?
Would customers require reformulation if regulatory requirements change?
A clear understanding of business exposure helps ensure comments remain relevant to the proposed rule.
Regulatory agencies typically find comments most useful when they contain objective information rather than broad statements of support or opposition.
Strong submissions may include:
Technical performance data comparing PFAS and alternative materials.
Manufacturing information describing process requirements.
Commercial analysis explaining supply chain impacts.
Scientific literature relevant to product performance.
Timelines required for qualification or reformulation.
Providing measurable information helps regulators understand how proposed requirements may affect real industrial operations.
Many specialty chemical applications rely on performance characteristics that can be difficult to replicate.
Procurement teams should evaluate whether commercially available alternatives exist and whether they meet required technical specifications.
Where substitutes remain under development, comments should explain:
Current technical limitations.
Product performance considerations.
Validation or testing requirements.
Customer qualification timelines.
Operational challenges associated with replacement.
Detailed technical explanations generally provide greater value than broad claims that alternatives are unavailable.
Procurement professionals often possess information that regulators may not receive from other stakeholders.
Useful commercial information can include:
Estimated qualification periods for replacement materials.
Inventory management considerations.
Supplier transition requirements.
Potential effects on downstream manufacturers.
Availability of alternative suppliers.
Providing practical examples supported by company experience helps demonstrate how regulatory decisions may influence supply chains beyond individual manufacturing facilities.
Well-structured submissions are easier for reviewers to evaluate.
A practical structure includes:
A brief description of the company and its activities.
An explanation of how the proposal affects operations.
Supporting technical or commercial evidence.
Specific recommendations related to the proposal.
References to supporting studies or documentation where appropriate.
Clear organization improves readability while helping reviewers locate key information efficiently.
With the hearing complete, procurement professionals should focus on preparing evidence-based written submissions before the July 20 deadline. Companies that depend on PFAS-containing products should review product portfolios, consult technical specialists, engage suppliers where necessary and identify information that accurately reflects operational realities. The EPA has stated that written comments submitted to the docket are an important part of the rulemaking process and will be considered as it evaluates the proposed rules.
Rather than relying on general policy statements, organizations should present practical information supported by technical, commercial and scientific evidence. Well-documented submissions not only strengthen the administrative record but also provide regulators with a clearer understanding of implementation challenges, supply chain considerations and the feasibility of alternative approaches.
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