
Daniel T. McKillop
Partner
201-896-7115 dmckillop@sh-law.com
Partner
201-896-7115 dmckillop@sh-law.com
On June 15, 2026, NJDEP adopted final PFAS remediation standards for PFNA, PFOA, PFOS, and GenX, converting interim criteria into enforceable requirements.
NJDEP has adopted final remediation standards for PFNA, PFOA, PFOS, and GenX, converting interim criteria into enforceable requirements under N.J.A.C. 7:9C, 7:26D, and 7:26E. The rule establishes a groundwater standard for GenX, incorporates stringent soil and soil leachate criteria, and requires PFAS evaluation where site conditions are uncertain. These changes embed PFAS into routine remediation and increase the likelihood that PFAS will drive investigation and cleanup obligations.
On June 15, 2026, the New Jersey Department of Environmental Protection adopted final site remediation standards for PFNA, PFOA, PFOS, and GenX. The rule amends the Remediation Standards rules, N.J.A.C. 7:26D, the Ground Water Quality Standards, N.J.A.C. 7:9C, and the Technical Requirements for Site Remediation, N.J.A.C. 7:26E, converting interim standards issued in 2022 and 2023 into binding requirements applicable to all remediation sites. In adopting the new standards, NJDEP emphasized that these widely used PFAS compounds present risks to public health, including impacts to immune response, liver function, and cancer risk, and that the rule is intended to protect drinking water and support enforcement against polluters. Additional information is available at NJDEP PFAS Standards and Regulations.
The adopted amendments to N.J.A.C. 7:9C, 7:26D, and 7:26E establish enforceable remediation criteria for PFNA, PFOA, PFOS, and GenX by converting prior interim standards into promulgated requirements. The rule includes a groundwater quality standard for GenX of 0.02 µg/L and incorporates soil and soil leachate standards across multiple exposure pathways. Fixed numerical criteria apply to direct exposure through ingestion and dermal contact, while migration to the groundwater pathway remains governed by site-specific analysis conducted using procedures consistent with N.J.A.C. 7:26D.
| Contaminant | Groundwater Standard (µg/L) | Soil Leachate Standard (µg/L) | Soil (Migration to Groundwater) | Residential Soil Standard (mg/kg) | Nonresidential Soil Standard (mg/kg) |
| PFNA | 0.013 | 0.26 | Site-specific | 0.047 | 0.67 |
| PFOS | 0.013 | 0.26 | Site-specific | 0.11 | 1.6 |
| PFOA | 0.014 | 0.28 | Site-specific | 0.13 | 1.8 |
| GenX (HFPO-DA) | 0.02 | 0.40 | Site-specific | 0.23 | 3.9 |
In addition to adopting the above standards, these amendments require NJDEP to evaluate PFNA, PFOS, PFOA, and GenX when contaminants are unknown or poorly documented. NJDEP indicated that these compounds were included due to their widespread use and prevalence in the State, reinforcing the expectation that PFAS be systematically addressed during site investigation.
The rule establishes enforceable cleanup thresholds and integrates PFAS into the core of site remediation practice in New Jersey. Responsible parties should anticipate broader sampling obligations, increased reliance on technical groundwater analysis, and a higher likelihood that PFAS contamination will drive remedial requirements and project timelines.
NJDEP’s adoption of final PFAS remediation standards formalizes a stringent regulatory framework to protect public health and drinking water resources. Although the numeric standards largely reflect prior interim criteria, their codification and expanded investigation requirements will affect site characterization, remedial design, and cost. Parties engaged in remediation or redevelopment should reassess PFAS risk, update due diligence practices, and incorporate these standards into ongoing compliance planning.
The firm’s Environmental Law Group is closely monitoring NJDEP’s evolving PFAS framework and its impact on remediation, redevelopment, and due diligence in New Jersey. If you have questions about how these final standards affect a current or contemplated project, or need help reassessing PFAS risk and compliance obligations, please contact Daniel T. McKillop or your Scarinci Hollenbeck attorney.
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