US EPA Releases 2026 PFAS Disposal Guidance: High-Temperature Incineration and Underground Injection Listed as Low-Risk Options

On April 20, 2026, the U.S. Environmental Protection Agency (EPA) released the 2026 Interim Guidance on PFAS Destruction and Disposal and opened it for public comment. This marks the third major update since the agency first issued the guidance in 2020. This update revises the guidance frequency from the legally required every three years to annual updates.

Core Highlights

1. Scope (Six PFAS Material Types)

Type	Description
Aqueous Film-Forming Foam (AFFF)	Firefighting foam
Soil and Biosolids	PFAS-contaminated sludge and soil
Industrial Textiles	Non-consumer items, such as protective clothing and tents
Spent Water Treatment Materials	Spent activated carbon, ion exchange resins, and high-pressure membranes
Landfill Leachate	PFAS-containing leachate
Industrial Waste	Solid, liquid, or gaseous waste generated from PFAS manufacturing or use

2. Three Disposal Technologies (Ranked from Lowest to Highest Environmental Release Risk)

Rank	Technology	Characteristics and Risks
1	Underground Injection (Class I Wells)	Lowest risk; injects liquid waste into deep geological formations, isolating it from underground drinking water sources; however, well numbers are limited, and it is only applicable to liquid wastes
2	Landfilling (RCRA Subtitle C Hazardous Waste Landfills)	Most stringent engineering controls (double liners, leachate collection); new research indicates PFAS releases from all landfills may be higher than 2024 estimates
3	Thermal Treatment (High-Temperature Incineration, etc.)	High temperatures (>1100°C), adequate mixing, and sufficient residence time can effectively destroy PFAS; however, there is a risk of products of incomplete combustion (PICs)

3. Key Updates (2026 Edition vs. 2024 Edition)

Thermal Treatment:

Added 2024 incinerator test data from Clean Harbors (Utah) and Veolia (Texas)
Added thermal treatment research on HFPO-DA (GenX)
Added research on Sewage Sludge Incinerators (SSI) and activated carbon reactivation furnaces

Landfills:

Added landfill liner permeability data
Added data on the impact of gas collection systems on PFAS migration
Updated leachate PFAS concentration range data
Added non-targeted analysis information

Underground Injection:

Updated Class I well distribution data (2023 data)

4. Primary Recommendations

General Principle: Prioritize technologies with lower environmental release risks

Specific Recommendations:

Liquid, high-concentration PFAS waste → Consider Class I underground injection wells
Solid PFAS waste → High-temperature thermal treatment (>1100°C) or RCRA Subtitle C hazardous waste landfills
Stable polymer-based PFAS (e.g., PTFE) → Permitted in various licensed landfills
Volatile/water-soluble PFAS → Require MSW landfills with composite liners plus leachate and gas collection systems
Not recommended: C&D landfills (typically lack liners and leachate collection)

Public Participation

The guidance is now entering a 60-day public comment period. The EPA specifically calls for: submission of research data related to PFAS waste management; collaboration from incineration facilities on PICs and emissions testing; and technology developers to publicly release data usable for the evaluation framework.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further Information

EPA

We have launched a LinkedIn newsletter to keep you up to date on the latest developments across the chemical industry including food and FCMs and personal and home care.