The Regulatory Landscape Has Changed
In April 2024, the EPA finalized the first-ever national drinking water standards for per- and polyfluoroalkyl substances, commonly known as PFAS or "forever chemicals." The rule established maximum contaminant levels (MCLs) for six individual PFAS compounds, including PFOA and PFOS at 4 parts per trillion (ppt) each, among the most stringent drinking water standards the EPA has ever set.
Water systems serving more than 10,000 people must comply by 2027, with smaller systems given until 2029. The compliance timeline is aggressive, and the scope of impact is vast. The EPA estimates that between 6,000 and 10,000 public water systems will need to take action, ranging from installing new treatment technologies to blending water sources or taking contaminated wells offline.
For companies selling treatment equipment, monitoring instrumentation, engineering services, and remediation technologies to water utilities, this regulation represents one of the largest market-creating events in a generation. But navigating the opportunity requires understanding both the technical requirements and the procurement dynamics.
What the MCLs Actually Require
The final rule sets individual MCLs for five PFAS compounds and a mixture-based hazard index for a group of four additional compounds:
- PFOA: 4 ppt
- PFOS: 4 ppt
- PFHxS: 10 ppt
- PFNA: 10 ppt
- HFPO-DA (GenX): 10 ppt
- Hazard Index of 1 for mixtures of PFHxS, PFNA, HFPO-DA, and PFBS
The 4 ppt standard for PFOA and PFOS is at the very edge of analytical detection capability. This has implications not just for treatment technology selection but for monitoring and laboratory capacity. Utilities must be able to reliably measure PFAS at these concentrations, and many commercial laboratories are still building out the capacity to handle the surge in testing demand.
Initial monitoring is required for all public water systems. Systems that detect PFAS above the MCLs must conduct quarterly monitoring and begin planning for compliance. The monitoring requirements alone are generating significant demand for analytical services and sampling equipment.
Treatment Technologies in Demand
Three primary treatment technologies have emerged as the workhorses for PFAS removal in drinking water applications:
Granular Activated Carbon (GAC) is the most widely deployed technology for PFAS removal. GAC adsorbs PFAS compounds as water passes through a bed of activated carbon media. It is effective for long-chain PFAS like PFOA and PFOS, relatively well-understood by utility operators, and available from multiple manufacturers. The primary cost driver is media replacement frequency: GAC beds must be replaced or reactivated periodically as they become saturated, and the replacement cycle depends heavily on the influent PFAS concentration and the presence of competing organic compounds.
Ion Exchange (IX) resins offer higher PFAS removal efficiency per unit of media compared to GAC, particularly for short-chain PFAS compounds that GAC handles less effectively. Single-use IX resins have become popular because they avoid the complexity of regeneration. However, the spent resin must be disposed of, typically through high-temperature incineration, which adds to lifecycle costs and raises questions about disposal capacity as IX deployment scales up.
High-pressure membranes, including nanofiltration (NF) and reverse osmosis (RO), can achieve very high PFAS removal rates, often exceeding 99 percent for most compounds. However, they produce a concentrated reject stream that must be managed, they have higher energy costs, and they remove beneficial minerals along with contaminants. Membrane systems are most commonly considered for systems with multiple co-occurring contaminants or where other technologies cannot meet the stringent 4 ppt standards.
A fourth category, PFAS destruction technologies, is emerging but not yet widely deployed at full scale. Technologies including electrochemical oxidation, supercritical water oxidation, and ultrasonication are being piloted at various scales. These are particularly relevant for managing the concentrated waste streams produced by GAC regeneration, IX disposal, and membrane reject. Vendors in this space are in a strong position for early-mover advantage, but utilities are cautious about adopting unproven technologies for compliance-critical applications.
The Market Sizing
The EPA's own regulatory impact analysis estimated the annual cost of compliance at $1.5 billion per year, with total costs over the first compliance cycle potentially reaching $12 to $15 billion. Independent analyses by the American Water Works Association and consulting firms have placed the estimates even higher, in some cases exceeding $20 billion when accounting for monitoring, system modifications, and ongoing operational costs.
This spending will flow through several channels:
- Capital equipment purchases for GAC vessels, IX systems, and membrane units
- Engineering and design services for treatment system integration
- Monitoring and analytical services for initial and ongoing PFAS testing
- Media and consumables including activated carbon, IX resins, and membrane elements
- Operations and maintenance contracts for systems that utilities lack the staff to operate in-house
- PFAS waste management and destruction for spent media and concentrated waste streams
The capital spending alone represents a multi-billion-dollar addressable market for treatment equipment manufacturers. But the recurring revenue from media replacement, monitoring, and O&M may ultimately exceed the upfront capital costs over a 10-year horizon.
Where the Funding Comes From
Compliance costs will be funded through a combination of sources. The BIL included $9 billion specifically for emerging contaminants, including PFAS, through the DWSRF. This money is available as grants or principal forgiveness loans, meaning utilities, particularly small and disadvantaged communities, may be able to fund PFAS treatment with minimal repayment obligation.
Several states have established their own PFAS remediation funds. Michigan, New Jersey, and New Hampshire have been among the most active, offering state-level grants and technical assistance for PFAS-affected systems. Some states have also pursued legal action against PFAS manufacturers, and settlement funds are beginning to flow to affected utilities.
The 3M PFAS settlement, announced in 2023, established a $10.3 billion fund for public water systems. Eligible systems are submitting claims through the settlement process, and these funds can be used for testing, treatment installation, and ongoing operation. Utilities that can document PFAS contamination and treatment needs are eligible regardless of whether they receive SRF funding.
For vendors, this multi-layered funding landscape means that the traditional objection, "we do not have budget for this," is weaker than it has been for any previous regulatory mandate. The combination of federal SRF grants, state funds, and settlement dollars means that many utilities will have access to capital specifically earmarked for PFAS compliance.
Procurement Implications for Vendors
Understanding the regulatory and funding landscape is necessary but not sufficient. Vendors also need to understand how utilities will procure PFAS treatment solutions.
Many utilities, especially smaller ones, will rely heavily on their state SRF program to fund PFAS projects. SRF-funded projects must comply with federal procurement requirements, including competitive bidding, Davis-Bacon prevailing wage requirements, and American Iron and Steel provisions. Vendors whose products or supply chains do not meet these requirements will be excluded from a large share of the market.
Engineering firms play a gatekeeping role in technology selection. Most utilities will hire an engineer of record to design their PFAS treatment system, and that engineer's familiarity with and confidence in a particular vendor's technology heavily influences the specification. Building relationships with the regional engineering firms that serve water utilities is critical for treatment equipment manufacturers.
Pilot testing is increasingly common for PFAS treatment projects, particularly for systems considering IX or newer technologies. Vendors who can offer turnkey pilot units with straightforward data collection and reporting capabilities will have an advantage in moving utilities from evaluation to procurement.
Timing Matters
The compliance deadlines are 2027 for large systems and 2029 for small systems. But design, permitting, and construction timelines mean that utilities need to be making technology decisions now. A large utility that has not yet begun its PFAS treatment design process is already behind schedule for 2027 compliance.
This creates urgency that favors vendors who can demonstrate proven performance, offer rapid deployment options, and help utilities navigate the funding application process. The window for influencing technology selection is open now and will begin closing as utilities finalize designs and move to procurement.
At United Current, we track PFAS monitoring data, SRF project lists, and treatment technology specifications across our coverage states. If you sell PFAS-related products or services, our platform can help you identify which utilities are actively planning treatment projects and where they are in the procurement process.
Related Resources
- How Much BIL Funding Has Actually Reached Water Utilities? — The $9B in BIL PFAS funding is part of the larger $55B picture. See where the money is flowing.
- 5 Signals That a Water Utility Is Ready to Buy — PFAS violations are one of the strongest buying signals. Learn which others to watch.
- How We Parse 50 Different State IUP PDF Formats — Behind the scenes on how we track SRF-funded PFAS projects across all 50 states.
- Solutions for Water Technology Vendors → — Find utilities with funded PFAS treatment projects and no vendor selected.
- Solutions for Engineering Firms → — Surface funded treatment plant upgrades, including PFAS remediation projects.