Trump EPA Releases First Regulatory Agenda of Second Term – Key Takeaways and Timelines

On September 4, 2025, the Trump Administration released the Spring 2025 Unified Agenda. The agenda is a comprehensive list of significant regulatory actions that all federal agencies intend to issue in the near and long term. The agenda shows the U.S. Environmental Protection Agency (EPA) continues to be one of the most active regulatory agencies across the federal government, as EPA announced just over 100 actions, many of which the agency had previewed in its March 2025 deregulatory initiative.

EPA’s listed actions also reflect the direction from President Trump to review, rescind, and revise numerous regulations issued under previous administrations. In particular, the actions underscore the administration’s initiatives to “Unleash American Energy,” scale back climate change-related rules, and streamline environmental permitting, as well as to generally reduce regulatory burdens.

The agenda includes EPA’s anticipated rulemaking timelines, which gives stakeholders important guidance for planning purposes, but these are not fixed deadlines. Interested companies may benefit from taking an active role now, engaging with EPA early on the issues that matter most to their operations. Below are some of the key takeaways and timelines of the agenda.

Expect Regulation of PFAS

EPA actions to address perfluoroalkyl and polyfluoroalkyl substances (PFAS) are a key feature of the agenda. Such action was expected as EPA announced the first-ever national PFAS Action Plan during the first Trump term. Some initiatives remain on the trajectory toward rulemaking, while some Biden-era measures are being recalibrated to prioritize flexibility and phased implementation.

• RCRA: EPA is proceeding with a Biden-era proposal to add nine specific PFAS[1] to the list of hazardous constituents under the Resource Conservation and Recovery Act (RCRA). If finalized, the rule will require corrective actions at treatment, storage, and disposal facilities where any listed PFAS have been released or may be released. A final rule is expected in April 2026.
• TSCA PFAS Reporting Rule: EPA is reconsidering the 2023 Toxic Substances Control Act (TSCA) regulation that broadly requires manufacturers (including importers) of PFAS and PFAS-containing products and articles between 2011-2022 to report certain data to EPA. EPA plans to incorporate exemptions and other modifications to the scope of these requirements. The proposed rule is expected in December 2025, with a final rule by June 2026.
• National Primary Drinking Water Regulations: In response to compliance challenges raised by public water systems and other stakeholders with the 2024 regulation, EPA is proposing a new rule to extend the compliance deadline for PFAS[2] in drinking water systems, thereby providing more time for utilities to implement treatment and monitoring programs. The proposed rule is expected in October 2025, with a final rule by April 2026. EPA is also proposing to withdraw its determinations to regulate four other PFAS compounds[3] under the Safe Drinking Water Act, with a proposed rule expected in September 2025 and a final rule in February 2026.

Revisiting Greenhouse Gas Rules

• Endangerment Finding and Motor Vehicle Greenhouse Gas (GHG) Standards Reconsideration: One of the most widely reported and potentially wide-reaching actions the Trump EPA has taken to date has been EPA’s reconsideration of the 2009 GHG Endangerment Finding and the 2024 GHG tailpipe emissions standards for motor vehicles and engines for model years 2012-2027 and beyond. EPA already published the proposed rulemaking in the Federal Register on August 1, 2025, with comments open until September 15, 2025. While the Regulatory Agenda predicts a final rule by September 2025, it is possible that date gets extended.
• Repeal of GHG Standards for Fossil Fuel Power Plants: EPA proposes to repeal the 2024 Carbon Pollution Standards that tightened GHG limits for new, existing, and modified fossil-fuel-fired power plants. The notice of proposed rulemaking (NPRM) was published on June 17, 2025; EPA now projects a final rule by December 2025.
• GHG Reporting Program Reconsideration: EPA will reopen the 2009 mandatory GHG reporting program and its amendments. The Regulatory Agenda initially forecasted that a proposed rule would be published in July 2025, though it has not yet been published. The agenda also expects a final rule in November 2025.
• Oil & Gas Methane Rule Reconsideration: EPA will reconsider oil and gas sector methane regulations under both the CAA § 111 New Source Performance Standards (NSPS) and the CAA Subpart W methane reporting program. On January 15, 2025, EPA issued an NPRM for the NSPS OOOOb/OOOOc programs, issuing an interim final rule extending compliance deadlines on July 31, 2025. The Regulatory Agenda forecasts a final rule by September 2025, which could change. On Subpart W, the Regulatory Agenda expected an NPRM by August 2025, which has not yet been issued, and a final rule by December 2025.
• HFC Phasedown Reconsideration: Responding to industry petitions, EPA will revisit portions of the American Innovation and Manufacturing (AIM) Act Technology Transitions rule, which phases in limits on the use of HFCs in subsectors like refrigeration or air conditioning. In a forthcoming rule, EPA plans to reconsider compliance times and the scope of applicability, covering industries such as refrigeration, semiconductor chillers, and HVAC systems. The Regulatory Agenda expected a proposed rule in July 2025, which has passed, as well as a final rule by December 2025.

Fuels Obligations

• Renewable Fuel Standard: EPA will establish renewable fuel volume requirements starting in 2026 for cellulosic biofuel, biomass-based diesel, advanced biofuel, and total renewable fuel. The NPRM was issued on June 17, 2025, and a supplemental proposal is currently pending OMB review. In the Regulatory Agenda, EPA projects a final rule by October 2025.

Air Permitting Rules Get a Fresh Look

• NSR “Begin Actual Construction” Definition: EPA will revise the New Source Review (NSR) definition of “begin actual construction” to clarify permissible pre-permit activities. The proposed rule is expected in January 2026, with a final rule by September 2026.
• NSR Public Participation Requirements for State Implementation Plans (SIPs): EPA will propose minimum public participation requirements for state and local NSR programs. The proposed rule is expected in January 2026, with a final rule by August 2026.

Renewed Debate on Interstate Ozone Transport

• 2015 Ozone National Ambient Air Quality Standards (NAAQS) – Phase 1 and 2 Transport Plan Review: EPA will revisit prior SIP disapprovals and FIPs addressing states’ interstate transport obligations under the 2015 ozone NAAQS. Multiple court stays affecting half of the states had been ordered following challenges to EPA’s past transport actions for the 2015 ozone NAAQS. For Phase 1, the Regulatory Agenda forecasted a proposed rule by August 2025, which has passed, and a final rule by December 2025. For Phase 2, a proposed rule is expected in October 2025, with a final rule due by August 2026.

Addressing risks posed by chemicals

• Reconsideration of TSCA Risk Evaluation Procedures: EPA is reconsidering the Biden Administration’s changes to the procedures used for conducting risk evaluations under TSCA (i.e., the method for determining whether a chemical substance presents an unreasonable risk of injury). EPA submitted a proposed rule to the Office of Management and Budget (OMB) for review, and final agency action is expected in April 2026.
• Chemical-Specific Regulations: EPA is proceeding with the statutorily required risk management regulations for the following high-priority designated chemicals: 1-Bromopropane (1-BP); N-Methylpyrrolidone (NMP); Formaldehyde; Methylene Chloride; and Cyclic Aliphatic Bromide Cluster (HBCD). Rulemaking is already underway for some of these chemicals — some of which were started under the previous administration — and others are expected to be proposed in the next year.

Noteworthy Rulemaking in the Queue

• Risk Management Plan (RMP) Reconsideration: EPA is reconsidering the 2024 RMP rule. Administrator Zeldin announced the action in March 2025, signaling a move back toward the 2019 framework, citing national security risks and burdens on refineries and chemical facilities. The Regulatory Agenda predicted a proposed rule by August 2025, which has passed, and a final rule by January 2026.
• National Emission Standards for Hazardous Air Pollutants (NESHAP) Reconsideration for Oil and Gas Sector: EPA will revisit the 2012 residual risk and technology review for hazardous air pollutants (HAPs) from oil and gas production and transmission/storage. EPA will issue a proposed rule by December 10, 2025, and a final rule by December 10, 2026.
• Meat and Poultry Effluent Limits: In 2024, EPA began a rulemaking to address and reduce allowable amounts of nutrient discharges (e.g., phosphorus and nitrogen) from meat and poultry product facilities. Although this rulemaking is listed in the Agenda, on September 3, the day before the Agenda was announced, EPA withdrew the proposed rule.

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As EPA continues its regulatory/deregulatory process, companies should consider their options for participating formally through public hearings and comment periods, as well as informally by engaging the agency, the Office of Management and Budget during interagency review, and other federal agencies and offices involved in the process.

[1] PFOA, PFOS, PFBS, GexX, PFNA, PFHxS, PFDA, PFHxA, and PFBA.

[2] Specifically, PFOA and PFOS.

[3] PFHxS, PFNA, GenX, and PFBS.

This post is as of the posting date stated above. Sidley Austin LLP assumes no duty to update this post or post about any subsequent developments having a bearing on this post.