PFAS Chromium Electroplating Wastewater Regulatory Update (Oct. 1, 2025)

Overview of Upcoming EPA Regulation

The U.S. Environmental Protection Agency (EPA) is in the process of developing new regulations to control polyfluoroalkyl substances (PFAS) in wastewater discharges from hard chromium electroplating operations. These efforts involve revising the Effluent Limitation Guidelines (ELGs) under the Clean Water Act. No specific limits have been proposed, however, background research suggests the discharge limits will be in the parts per trillion range. 

The Office of Management and Budget's Spring 2025 Unified Agenda Notice of Proposed Rulemaking (NPRM) for revising the Metal Finishing Effluent Limitation Guidelines indicates a date of July 26, 2026 to address discharges of PFAS. An NPRN is a public announcement in the Federal Register that signals a government agency's intent to issue or modify regulations. A final rule, if proposed, is expected at least six to twelve months after the NPRM, which suggests implementation could occur no earlier than 2027.

Background: Air and Water Regulation of Chromium Electroplating

Air emissions from chromium electroplating are regulated under the Chromium NESHAP for Decorative and Hard Chromium Electroplating and Chromic Acid Anodizing. Compliance with these air regulations is often achieved using fume suppressants. Suppressants work by lowering the surface tension of the plating bath, resulting in smaller bubbles that rise more slowly and form a foam layer. This foam acts as a barrier, preventing the escape of chromic acid mist and controlling air emissions.

While fume suppressants are effective for reducing air pollution, they can inadvertently contribute to water pollution through dragout and rinsing processes. Historically, most suppressants contained perfluorooctane sulfonate (PFOS), a highly fluorinated chemical that is a specific type of PFAS. Recognizing the link between suppressants and water contamination and concern over PFOS, EPA revised the chromium NESHAP in 2012 to prohibit PFOS-based suppressants effective September 21, 2015 (40 CFR 63, Subpart N).

The 2012 NESHAP regulations define "PFOS-free" suppressants as those containing less than one percent PFOS by weight. However, given that future wastewater limits are expected to be in the parts per trillion range, the one percent definition is incompatible with the expected wastewater limit. Effluent standards at such low levels would require mist suppressant products to contain essentially zero percent PFAS/PFOS.

Current Market: Certified Non-PFOS Wetting-Agent Chemical Fume Suppressants

Non-PFOS suppressants (at or very near zero percent) are formulated with alternative chemicals, such as surfactants, which provide effective fume suppression without PFOS. Over the past decade, various research has focused on non-PFOS alternatives, and the California Air Resources Board (CARB) appears to be a leading authority in this area, having published a list of Certified Non-PFOS Wetting-Agent Chemical Fume Suppressants in October 2023. This list includes five commercial products: two are suitable for hard chrome plating, and three are intended for decorative chrome plating and chromic acid anodizing.

Additional Information and EPA Actions

Administrator Zeldin Announces Major EPA Actions to Combat PFAS Contamination (April 2025). EPA Administrator Zeldin announced actions to address PFAS contamination. These include developing new ELGs for PFAS manufacturers and metal finishers, as well as evaluating additional ELGs to further reduce PFAS discharges.

Sampling and Analysis of PFAS in Fume Suppressants at Electroplating Facilities (June 2020).  EPA scientists conducted targeted and non-targeted laboratory analyses of fume suppressants at electroplating facilities. They examined 12 fume suppressant samples and 11 effluent samples collected prior to PFAS treatment. None of the currently used suppressants contained detectable PFOS or PFOS precursors, indicating that replacement products did not break down into PFOS. Additional details can be found in the 2020 EPA report.

PFAS in the Metal Plating and Finishing Industry (December 2022). This report provides information about PFAS use in the metal plating and finishing industry, including environmental release pathways and source reduction strategies.