What Happens After the July 20 PFAS Comment Deadline? Understanding the EPA Rulemaking Process

The July 20 PFAS comment deadline may appear to be a major turning point, but it does not mark the end of the EPA's regulatory process. For chemical suppliers, water utilities and procurement professionals, understanding what follows is just as important as understanding the proposal itself.

Many businesses mistakenly assume that once public comments close, new regulations immediately take effect. In reality, the EPA must complete several additional steps before any proposed changes become final. That process often extends for months or even years, particularly when complex environmental regulations face significant public interest and legal scrutiny.

The Comment Deadline Closes Only One Stage

The July 7 public hearing and the July 20 written comment deadline complete the public participation phase of the current rulemaking process. During this period, stakeholders have the opportunity to submit technical evidence, legal arguments, economic analysis and public policy recommendations.

Once the deadline passes, the EPA does not immediately issue a final decision. Instead, the agency begins reviewing every submission received during the comment period.

This review forms an essential part of federal rulemaking because agencies must demonstrate that they considered significant comments before adopting a final regulation.

What the EPA Does After July 20

Following the close of the comment period, the EPA enters a detailed review process. Agency experts evaluate submissions from water utilities, environmental organizations, chemical manufacturers, industry associations, scientists, public health groups and members of the public.

The EPA must identify major issues raised throughout the record and determine whether those comments justify changes to the proposed rule.

Key activities during this stage include:

• Reviewing technical evidence submitted by stakeholders.

• Evaluating legal arguments regarding the Safe Drinking Water Act.

• Assessing comments related to implementation costs and compliance timelines.

• Preparing formal responses to significant issues raised during the comment period.

This work requires considerable time because every substantial argument must receive appropriate consideration before the agency publishes its final decision.

Publication in the Federal Register

After completing its review, the EPA prepares the final rule for publication in the Federal Register.

The published rule explains the agency's final position, addresses important public comments and presents the legal and technical reasoning supporting the decision. Only after publication does the rule become official federal regulatory action.

The final version may match the original proposal, include revisions based on public feedback or adopt a different approach altogether. For procurement teams, this means planning should remain flexible until the final text becomes available.

Why the Timeline Often Takes Months or Years

Environmental regulations rarely move quickly from proposal to implementation. Scientific complexity, legal requirements and the volume of submitted comments all contribute to lengthy review periods.

The PFAS proposal involves drinking water standards that affect municipalities, manufacturers, laboratories, treatment technology providers and public health organizations across the country. Each of these groups may submit detailed technical information requiring careful evaluation.

As a result, buyers should not expect immediate regulatory certainty once the July 20 deadline passes.

Litigation Could Extend the Timeline Further

Even after EPA publishes a final rule, the regulatory process may continue through the courts.

According to Jones Day's published analysis, "litigation is widely expected regardless of the outcome." If the rescission becomes final, environmental and public health organizations may challenge the decision. If the EPA decides not to finalize the rescission, industry groups may pursue legal action instead.

This possibility means publication in the Federal Register may represent the beginning of another phase rather than the conclusion of the regulatory process.

Existing Legal Challenges Also Continue

The regulatory landscape already includes ongoing litigation.

The 2024 PFAS drinking water rule remains subject to pending legal challenges before the D.C. Circuit. Those proceedings continue independently of the current proposal and may influence how the broader regulatory framework develops.

For businesses, this creates a situation where both rulemaking and litigation occur simultaneously. Understanding both processes helps organizations avoid making decisions based solely on a single regulatory milestone.

What Procurement Teams Should Focus On

Chemical buyers and water treatment professionals should avoid treating July 20 as a deadline for immediate operational changes.

Instead, procurement strategies should emphasize flexibility and continuous monitoring.

Consider the following priorities:

• Continue tracking EPA announcements after the comment period closes.

• Monitor publication of the final rule in the Federal Register rather than relying only on hearing or comment dates.

• Watch for litigation developments that could affect implementation timelines.

• Maintain communication with suppliers regarding treatment chemicals and compliance products.

• Build procurement plans that can adapt if regulatory requirements change during the review process.

This approach reduces the risk of making costly purchasing decisions based on incomplete regulatory information.

The Bottom Line for Procurement Teams

The July 20 PFAS comment deadline represents an important milestone, but it is only one step in a much longer federal rulemaking process. After the deadline, the EPA must review submitted comments, respond to significant issues and publish a final rule before any proposed changes become effective.

Because this process typically takes months to years and litigation remains likely regardless of the outcome, procurement professionals should base compliance planning on realistic regulatory timelines rather than assuming the hearing or comment deadline marks the end of the process.

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