September 16, 2025
As U.S. cannabis beverage manufacturing races into the mainstream, a regulatory wave is cresting that few in the industry can afford to ignore. With the EPA’s newly finalized PFAS drinking water standards (enforceable starting in 2025) and the expansion of Resource Conservation and Recovery Act (RCRA) waste rules to encompass PFAS, THC- and cannabinoid-infused drink makers need urgent action—not just lip service—on environmental compliance.
In April 2024, the EPA finalized the first-ever, legally-enforceable national drinking water standards for PFAS (per- and polyfluoroalkyl substances)—commonly labeled “forever chemicals” for their resistance to environmental breakdown. Compliance with these maximum contaminant levels (MCLs) for several PFAS chemicals must be achieved by most public water systems within a 3–5 year window, but the race is already on for supply chain partners. (Federal Register Notice, EPA Key PFAS Actions)
Meanwhile, EPA and state agencies are tightening scrutiny on all waste streams containing PFAS—including those generated by infused beverage manufacturing (think: plant washwater, spent filtration media, and packaging waste). Through both RCRA hazardous waste amendments (enforcement ongoing in 2025–2026) and stricter local discharge permits, the cannabis beverage sector faces new obligations.
States have not waited for federal action—over 350 PFAS-related bills introduced across 39 states in 2025 reflect a broad policy appetite for bans, disclosure, and cleanup. Five states—Illinois, Virginia, Maine, New York, and New Mexico—enacted major bills targeting intentionally added PFAS in consumer products and water supplies. Most notably:
Alongside packaging regulations, states and municipalities are moving swiftly to lower PFAS discharge limits through updated wastewater pretreatment programs. Many local Publicly Owned Treatment Works (POTWs) are enforcing reporting, sampling, and best management practices (BMPs) for industrial users—infused beverage plants included. (See recent overviews at NCEL and 3Eco).
Key takeaway: Federal and state rules are rapidly compounding. Failure to proactively assess your waste streams and supply chain now risks shutdowns, fines, and loss of market access in 2025–2026.
If you think PFAS is only a water issue, think again. Infused beverage operations face multi-faceted exposure points:
Municipal or well water used in cannabis beverage production must now be tested for PFAS. Expect question from local POTWs and water authorities on intake, discharge, and how you manage contaminants.
Many shelf-stable and nano-emulsion beverages use additives (e.g., emulsifiers, surfactants) that may be sourced from suppliers relying on PFAS-based processing aids. Do you have supplier documentation?
Activated carbon and membrane filters effectively remove cannabinoids and off-flavors—but can accumulate PFAS. Spent filters and media may be classified as hazardous waste.
Aluminum cans, tetra packs, and flexible pouches often feature PFAS-based liners or coatings for shelf life. These are under direct threat of state bans for new production—and legacy stock may be non-compliant by 2027.
Regular cleaning and maintenance of tanks, lines, and surfaces produces wastewater that may contain PFAS. These volumes need proactive evaluation under state-local discharge permits and RCRA.
The EPA’s RCRA expansion, as highlighted in the EPA Spring 2025 agenda, clarifies that:
Step 1: Map Your Waste Streams
Step 2: Inventory Inputs for Potential PFAS Content
Step 3: Sample and Analyze
Step 4: Document and Classify
Step 5: File and Review Annually
For a customizable audit template and compliance tools, see CannabisRegulations.ai’s PFAS resources.
Review all supplier Safety Data Sheets (SDS) for PFAS content and request explicit declarations of PFAS-free status.
Include PFAS compliance clauses in all supply contracts and request updated safety and environmental declarations before 2026.
With enforcement ramping up, leading retailers, insurers, and local water utilities will require written evidence of PFAS and RCRA compliance;
Bonus Tip: Store all compliance files digitally and back up offsite; audit requests can arrive with little notice, and failure to produce documentation can trigger penalties, denial of insurance claims, or contract cancellations.
For a customizable audit template, compliance checklists, and the latest alerts on PFAS, RCRA, and cannabis beverage regulations, visit CannabisRegulations.ai and empower your operations for 2025 and beyond.
