How To Navigate PFAS Compliance Moving Into 2026
Australia has taken a major step forward in 2025, in managing PFAS contamination with the release of the PFAS National Environmental Management Plan (NEMP) 3.0. The PFAS National Environmental Management Plan (PFAS NEMP) is Australia’s national guide for managing Per- and poly-Fluoroalkyl substances (PFAS) contamination in the environment. Endorsed by environment ministers in late 2024 and published in March 2025, this update replaces the PFAS NEMP 2.0 and introduces significant changes that will impact industries across the country, moving into 2026.
What are PFAS and why do they matter?
PFAS are synthetic chemicals widely used for their resistance to heat, water, and oil. They are found in firefighting foams, textiles, food packaging, and many industrial applications. However, PFAS are highly persistent in the environment and can accumulate in humans and wildlife, posing long-term health and ecological risks.
From 1 July 2025, the Australian Government placed a ban on the manufacture, importation, exportation or use of PFAS, including PFOS, PFOA, and PFHxS or any products containing them. Although this is a step in the right direction, Waster Services Association of Australia (WSAA) has recommended that the Federal Government takes stronger measures to prevent further PFAS pollution in Australia.
This includes the following actions:
1. Ban or restrict PFAS in non-essential consumer products;
2. Implement mandatory labelling and disclosure requirements;
3. Develop and implement a National Contaminants Strategy; and
4. Implement national coordination of source control, monitoring, and remediation of contaminants.
The NEMP 3.0 is to be used, as a framework for Australian businesses to ensure PFAS compliance.
The key updates in the PFAS NEMP 3.0 (2024/2025):
1. Updated Guideline Values
NEMP 3.0 introduces revised health-based and ecological guideline values for soil, surface water, groundwater, and biota. These updates improve risk assessment for both human health and ecosystems compared to NEMP 2.0.
2. Enhanced Remediation Guidance
NEMP 3.0 has a stronger emphasis on remediation hierarchies, prioritizing treatment over disposal. It also provides new guidance on demonstrating remediation success and managing long-term residual risk. NEMP 2.0 focused more on containment and disposal; NEMP 3.0 shifts toward sustainable treatment solutions.
3. Resource Recovery & Circular Economy
New risk-based criteria were introduced for reusing biosolids and other resource recovery products contaminated with PFAS. NEMP 3.0 includes frameworks for safe reuse decisions based on site-specific risk assessments. NEMP 2.0 had limited guidance on reuse; NEMP 3.0 supports the goals of the circular economy while protecting health and the environment.
4. Expanded Monitoring & Sampling Protocols
Clearer expectations for ambient vs. site-specific monitoring. Updated approaches for PFAS sampling, leachability testing, and lab analysis, including newer PFAS variants and precursors. NEMP 2.0 had basic monitoring guidance; NEMP 3.0 significantly strengthens this area.
5. National Consistency
NEMP 3.0 reinforces uniform assessment and management approaches across all jurisdictions, providing clearer pathways for risk-based decision-making and compliance alignment.
6. Supporting Documents
NEMP 3.0 includes detailed supporting documents that were not as comprehensive in NEMP 2.0. These include:
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Biosolids criteria derivation.;
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Ecological guidelines for wildlife diet and soil exposure; and.
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Human health soil guideline values.
In short:
NEMP 3.0 is more risk-based, treatment-focused, and aligned with the principles of the circular economy, while NEMP 2.0 was primarily about containment and basic guideline values.
What does this mean for businesses going into 2026?
The implications are significant across multiple sectors:
Manufacturing & Importers:
With PFOS, PFOA, and PFHxS now banned under IChEMS from July 2025, businesses must phase out PFAS-containing products and document compliance.
Construction & Infrastructure:
Projects involving contaminated soil or groundwater will require updated risk assessments and remediation strategies aligned with NEMP 3.0.
Waste & Resource Recovery:
Operators must meet new PFAS thresholds for biosolids and recovered materials, impacting reuse and disposal practices.
Water Utilities & Industrial Dischargers: Stricter discharge limits and monitoring requirements will drive investment in advanced treatment technologies.
Agriculture & Food Production:
Risk-based frameworks for biosolids reuse will influence soil management and crop safety.
Our Expertise: How Peter J Ramsay & Associates Can Assist
PFAS Risk Identification and Assessment
Site Investigations: Conduct detailed soil, groundwater, and surface water sampling using updated NEMP 3.0 protocols.
Risk Profiling: Apply revised guideline values for human health and ecological protection to determine compliance gaps.
Exposure Pathway Analysis: Use enhanced tools for risk-based decision-making to tailor assessments for specific industries.
Compliance Strategy Development
Gap Analysis: Compare current operations against NEMP 3.0 requirements for biosolids, resource recovery, and discharge limits.
Action Plans: Develop staged compliance strategies aligned with jurisdictional timelines and EPA expectations.
Regulatory Liaison: Engage with state EPAs to ensure approvals and reporting meet new standards.
Remediation and Treatment Solutions
Remediation Hierarchy: Shift from containment to treatment, as NEMP 3.0 prioritizes destruction of PFAS over disposal.
Technology Selection: Advise on advanced PFAS removal technologies (e.g., adsorption, ion exchange, thermal destruction) that meet EPA-backed performance criteria.
Verification: Provide independent validation of treatment outcomes to demonstrate compliance.
Resource Recovery and Circular Economy Compliance
Biosolids Management: Apply new risk-based criteria for reuse of biosolids and recovered materials.
Safe Reuse Frameworks: Develop site-specific assessments for construction, agriculture, and waste sectors to enable compliant reuse.
Documentation: Prepare compliance reports for regulators and clients to support sustainable practices.
Monitoring and Reporting
Expanded Monitoring Programs: Implement ambient and site-specific monitoring plans using updated sampling and leachability protocols.
Data Management: Use environmental data platforms to ensure traceability and comparability across jurisdictions.
Ongoing Compliance Audits: Conduct periodic reviews to maintain adherence as standards evolve.
PFAS Dashboard
In collaboration with Antea Group USA, PJRA and the Inogen Alliance have developed the Global PFAS Regulatory Dashboard, which offers access to PFAS regulatory data that is updated frequently. This tool aims to assist organisations to navigate regulatory requirements and ensure consistent compliance across multiple locations.
Use the free version to:
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Explore PFAS regulations across regions;
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Monitor new and pending regulatory actions; and
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Compare requirements country to country.
Thank you to our colleague, Annika Taylor, for working with the Inogen Remediation Working Group, and Antea Group USA, to lead the way in global environmental compliance.