EPA’s 2025 PFAS Drinking Water Changes: What THC and CBD Beverage Manufacturers Must Fix

Overview: PFAS Drinking Water Rule 2025 and Its Cannabis Beverage Impact

In 2024, the U.S. Environmental Protection Agency (EPA) finalized its first nationwide enforceable drinking water standards for several per- and polyfluoroalkyl substances (PFAS). This landmark rule included maximum contaminant levels (MCLs) for key PFAS such as PFOA and PFOS, set at 4 parts per trillion (ppt) each. In May 2025, the EPA announced significant modifications and extended compliance deadlines, providing new lead time and regulatory uncertainties for all beverage manufacturers, including fast-growing THC and CBD beverage brands.

While public water systems remain the primary compliance point, the cannabis beverage sector—which relies on large volumes of municipal or well water for infused seltzers, teas, and ready-to-drink cannabinoids—must urgently address PFAS as a comprehensive supply chain and facility water risk.

This blog demystifies the 2025 PFAS drinking water rule, litigation status, and the steps cannabis beverage producers must take to stay compliant and protect both consumers and their brands.

What Changed in the EPA’s 2025 PFAS Drinking Water Rule?

New Federal Mandates—With Delayed Timelines

The initial 2024 rule set strict national PFAS limits:

• PFOA and PFOS: 4 ppt maximum contaminant level (MCL) each
• Additional PFAS (PFHxS, PFNA, GenX, PFBS): Various MCLs, subject to revision

As of May 2025, EPA:

• Retained MCLs for PFOA and PFOS at 4 ppt
• Extended the national compliance deadline for these two chemicals to 2031
• Announced plans to rescind and reconsider MCLs for other PFAS (PFHxS, PFNA, GenX, PFBS)—resulting in ongoing regulatory and legal debates (source)
• Renewed litigation in July 2025 challenging scope and stringency (EPA News)

What Does This Mean for Beverage Manufacturers?

Although primary water system compliance deadlines are delayed, beverage brands remain exposed to:

• Public relations and liabilities from product PFAS detections
• Retailer and consumer demand for PFAS-free claims
• Patchwork of ongoing state-level and supply chain PFAS standards
• Brand protection and risk management obligations

Why Cannabis Beverages Face Special PFAS Compliance Pressure

The cannabis beverage segment is especially impacted because:

• Dilution water often constitutes the majority of the finished product.
• Some operators use private wells, not just public water.
• Product marketing often features “clean” or “natural” claims—making any contaminant riskier.
• Many state cannabis compliance frameworks now reference water quality and ingredient COAs (certificates of analysis).
• PFAS is not usually captured by routine cannabis potency or pesticide tests—requiring new supplier oversight.

In short, the evolving PFAS drinking water rule 2025 cannabis beverages compliance landscape is both a regulatory and reputational battleground for infused product makers.

The PFAS Risk Control Checklist for THC + CBD Drinks

1. Add PFAS Specifications to Incoming Water and Ice

Define maximum PFAS levels (e.g., below 4 ppt for PFOA/PFOS) in internal ingredient specs and supplier agreements. Require:

• Updated municipal "compliance letters" on PFAS monitoring
• Third-party water lab results demonstrating PFAS levels, especially for private well or small system sources
• Verification that ice suppliers (if used) meet the same criteria

2. Assess Facility Water Treatment and Risks

• For manufacturers in PFAS-impacted zones (see maps via EPA), assess need for on-site GAC (Granular Activated Carbon) or RO (Reverse Osmosis) polishing
• Document maintenance and validation of filtration systems
• For mobile or contract production, confirm each site’s water quality individually

3. Update HACCP / Food Safety Plans with PFAS Hazards

• Address PFAS as a chemical hazard in HACCP or Preventive Controls (PCQI) plans
• Establish routine monitoring, corrective action, and supplier approval processes
• Strengthen audit checklists for water and ingredient sourcing

4. Review Ingredient COAs—Don’t Assume PFAS is Tested

• Work with labs that can provide PFAS panels—most cannabis testing does not automatically include these analyses
• Require PFAS reporting on major ingredients: water, ice, botanicals, flavorings
• Maintain documented responses for regulator or retailer queries

5. Scrutinize Marketing and Product Claims

• Do not use “PFAS-free” on label or marketing unless it can be strictly substantiated (zero detected, ongoing lot-by-lot testing, and defensible supply chain proof)
• Opt for “rigorously tested for water quality” or “compliant with all federal standards” language instead
• Stay alert for class action challenges related to “PFAS-free” or “clean label” claims

6. Separate Packaging Compliance from Water Safety

• New PFAS restrictions also apply to food and beverage packaging materials, but under different (often state-based) rules, not the drinking water standard (more from NRDC)
• Coordinate internal compliance files so that any “healthy” or “clean” claims are backed up on both water and packaging fronts

Litigation, Enforcement, and Future Uncertainty

National and State Enforcement Outlook

While public water supplies have until 2031 to achieve compliance for PFOA and PFOS, brand and product liability can arrive much sooner—especially if retailers, distributors, or state inspectors request PFAS disclosures.

As of July 2025:

• Several lawsuits are challenging the scope of the PFAS rule, especially the inclusion/exclusion of additional PFAS beyond PFOA/PFOS (see VAMWA PDF analysis).
• Many states (CA, NY, MI, MN, WA) maintain stricter or earlier PFAS water and packaging rules for beverage/food products—expect retail/grocery buyers to reference state-level lists in procurement requirements.

What Will Be Enforced?

• Water used in beverage manufacturing must come from PFAS-compliant sources per primary water system records or, for well users, third-party lab data
• Documentation of supplier and batch-level water quality checks will likely be requested in any food safety, beverage, or cannabis compliance audit
• Lapses or false PFAS-free claims risk consumer actions, retailer delistings, and possible state/federal penalties

Key Takeaways: Cannabis Beverage Brands—Do Not Wait for 2031

1. Treat PFAS as a current food-safety and brand risk—even with delayed federal deadlines
2. Update supplier SOPs now to mandate incoming water, ice, and major ingredient PFAS reporting
3. Invest in routine PFAS testing and filtration where your municipal source is uncertain or above new MCLs
4. Revise all product claims and documentation—avoid “PFAS-free” or “clean label” marketing unless you maintain ongoing proof and oversight of both water and packaging
5. Monitor litigation and changing rules, especially if you operate across state lines with stricter PFAS standards than the federal baseline

For the latest on PFAS drinking water rule 2025 cannabis beverages compliance—including compliant supplier templates, audit checklists, and state-by-state requirements—turn to CannabisRegulations.ai for actionable compliance solutions and regulatory monitoring.