The United States Environmental Protection Agency (EPA) has released a 2026 update to its Interim Guidance on the Destruction and Disposal (DDG) of Per- and Polyfluoroalkyl Substances (PFAS) and PFAS-Containing Materials. This update reflects scientific information and data reviewed through September 2025 and builds on prior versions issued in 2020 and 2024 under direction from the 2020 National Defense Authorization Act (NDAA). EPA has committed to updating the interim guidance annually.
EPA’s interim guidance does not establish regulatory requirements. Instead, it provides recommendations, summarizes current scientific understanding, and outlines considerations that decision-makers can use to evaluate destruction and disposal options responsibly.
The primary audience for the 2026 interim guidance includes decision‑makers responsible for managing PFAS and PFAS‑containing materials, such as facility managers, utilities, waste owners, and others who must determine how PFAS wastes are destroyed, disposed, or stored.
Because PFAS wastes vary widely in chemical composition, physical phase, concentration, volume, and location, EPA explicitly recommends that managers evaluate options based on site‑specific conditions, waste characteristics, infrastructure availability, costs, and potential impacts to nearby communities.
Scope of PFAS Materials Addressed
Consistent with the FY 2020 NDAA, the interim guidance on the destruction and disposal of PFAS focuses on PFAS-containing materials and wastes including:
- Aqueous film-forming foam (AFFF)
- Contaminated soils and biosolids
- PFAS-treated textiles
- Spent filters, membranes, resins, and granular activated carbon (GAC) from water treatment
- Landfill leachate containing PFAS
- Solid, liquid, or gaseous waste streams from facilities manufacturing or using PFAS
Technologies and Approaches for the Destruction and Disposal of PFAS
EPA’s interim guidance focuses on three widely used, large-capacity, matured, and commercially available destruction and disposal of PFAS approaches, recognizing that each comes with benefits, limitations, and uncertainties. In practice, PFAS management strategies often involve treatment trains (e.g., adsorption or membrane concentration followed by destruction or disposal), rather than reliance on a single technology.
These technologies are discussed in terms of their ability to destroy PFAS or control PFAS releases across solid, liquid, and gas-phase waste streams. EPA prioritizes evaluation of potential release pathways, including:
- Volatilization
- Air dispersion
- Leachate formation
- Long-term migration
The guidance document also discusses emerging technologies and provides a framework for evaluating emerging technologies for PFAS destruction or disposal. such as:
- Mechanochemical degradation
- Gasification and pyrolysis
- Supercritical water oxidation
Not all technologies achieve complete mineralization of PFAS to carbon dioxide and fluoride; some may transform PFAS into shorter-chain compounds or products of incomplete destruction, which remain environmentally persistent.
Many emerging technologies show promise for PFAS destruction; however, most remain at pilot or early commercial scale or are claimed as proprietary, and EPA emphasizes the need for transparent, publicly available performance data to support validation and comparison across technologies.
Underground Injection for Disposal and Destruction of PFAS
EPA identifies permitted Class I non-hazardous or Class I hazardous waste injection wells as an option with a lower potential for PFAS release when properly constructed, operated, and monitored. These wells are designed to isolate liquid wastes deep underground and protect underground sources of drinking water.
However, EPA also notes that underground injection may not be appropriate or available in all locations due to geologic, regulatory, or infrastructure constraints. Selection of non-hazardous disposal pathways may carry long-term regulatory and liability considerations if PFAS are later designated as hazardous under federal or state programs.
Disposal of PFAS at Landfills
When landfill disposal is selected, particularly for materials with relatively high PFAS concentrations, EPA recommends permitted RCRA Subtitle C hazardous waste landfills, which have the most stringent engineering controls for minimizing PFAS releases through leachate and landfill gas.
At the same time, EPA highlights new information indicating that PFAS releases from landfills may be higher than previously understood, underscoring the importance of landfill design, controls, and long‑term monitoring. Long-term performance considerations include leachate management, landfill gas controls, and the effectiveness of downstream treatment systems in managing PFAS-containing residuals.
Thermal Treatment Under Specific Restraints
Since the 2024 guidance, additional research has shown promising results for thermal treatment technologies operating under specific conditions (i.e., more than 1,000℃ and sufficient residence time), including certain hazardous waste combustors and some granular activated carbon reactivation units.
EPA emphasizes, however, that uncertainties remain, particularly for units operating at lower temperatures or with different waste types. New EPA analytical methods are intended to improve detection of byproducts such as products of incomplete combustion (PICs) and PFAS air emissions. EPA’s focus on PICs highlights the importance of evaluating both stack emissions and secondary residuals, including scrubber water and ash.
As a result, EPA encourages facility‑specific testing before large‑scale acceptance of PFAS‑containing materials at thermal treatment facilities. Comprehensive mass balance evaluations are increasingly recognized as critical to understanding PFAS fate across air, water, and solid residual streams.
EPA’s Decision‑Making Framework: Relative Potential for PFAS Release
Rather than ranking technologies by effectiveness alone, EPA evaluates destruction and disposal options based on their relative potential to release PFAS into the environment. “Lower potential for release” refers to minimizing PFAS migration across environmental media (air, water, and soil), rather than solely maximizing destruction efficiency.
As a general approach, EPA recommends that decision‑makers:
- Prioritize technologies with a lower potential for PFAS release, particularly when costs and logistics are similar
- Consider whether a technology achieves destruction, transformation, or long-term containment of PFAS
- Account for waste characteristics, including PFAS chemistry, phase, concentration, and volume
- Evaluate site‑specific infrastructure constraints and transportation logistics
- Distinguish between potential environmental release and actual human exposure and risk
- Recognize that real-world performance and testing data for the top three technologies are limited and uncertainty remains regarding actual destruction/disposal effectiveness and environmental impacts
EPA also highlights that interim storage with appropriate controls may be a short-term option for certain PFAS wastes when immediate destruction or disposal is not feasible and where long-term solutions remain uncertain or capacity constrained.
Data Gaps
Despite progress, EPA has identified several data gaps, including reliable measurement of PFAS and breakdown products, full-scale destruction performance data, fate and transport of PFAS in landfills and injection zones, effectiveness of leachate and landfill-gas treatment, and long-term performance data for emerging technologies.
Why This Matters for Organizations Today
The 2026 interim guidance reflects EPA’s current expectations for informed, risk‑based decision‑making and signals where future regulatory and scientific focus is headed.
Organizations that proactively evaluate options, engage with evolving guidance, and seek technical support are better positioned to manage long‑term environmental, regulatory, and risk. This includes increased emphasis on vendor due diligence, evaluation of technology performance data, and documentation of decision rationale to support future regulatory and stakeholder scrutiny.
Bottom Line
The most recent version of the disposal and destruction guidance of PFAS highlights high-temperature thermal treatment as a potentially effective protective approach under specific operating conditions, while emphasizing data gaps and ongoing uncertainty across all destruction and disposal pathways, including landfilling and underground injection. Overall, the guidance reinforces that no PFAS destruction or disposal option is currently without uncertainty, shifting the focus toward managing relative risk across available options rather than identifying a single preferred solution.
