New monitoring framework for PFAS substances in wastewater treatment plants

A new circular and a decree from April 2026 strictly regulate the monitoring and management of PFAS in wastewater treatment plant (WWTP) sludge intended for agriculture, and expand the scope of TFA testing in wastewater.

Juliette Virly
Consultante HSE
Publication : 
17.06.2026
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🔎 Key takeaways

  • Mandatory testing campaign: Wastewater treatment plants (WWTPs) serving more than 10,000 population equivalent (PE), as well as those associated with the textile and paper industries, must analyze quarterly for 12 months 52 PFAS substances in their sludge intended for agricultural use (land application, composting, anaerobic digestion).
  • Future expansion and long-term framework: This monitoring obligation will be extended to "small" WWTPs (less than 10,000 PE) during 2027, when ministerial decrees will establish a long-term management framework.
  • Strict management of polluted sludge: In case of exceeding regulatory thresholds (POP regulation or the list of 22 PFAS), operators must destroy the sludge by incineration, identify pollution sources, and analyze the soil of agricultural plots that have received sludge over the past 5 years.
  • Addition of TFA and deadline postponement: For influent and effluent of urban WWTPs,trifluoroacetic acid (TFA) is a mandatory addition to the list of PFAS to be monitored. In return, the deadline for carrying out this water monitoring campaign is postponed to June 30, 2027 (instead of end 2026).

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    Please note: This article concerns French legislation. The requirements described may not apply in other countries.

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    As a reminder, the interministerial action plan on PFAS, implemented in 2024, aims to reduce the exposure of the population and the environment to PFAS substances. It specifically includes an action to characterize PFAS levels in fertilizing materials, including sludge from wastewater treatment plants. 

    In this context, the circular of April 27, 2026, specifies the framework for monitoring and managing sludge from wastewater treatment plants intended for agricultural use*. It thus requires operators of certain wastewater treatment plants to carry out measurement campaigns for PFAS substances.  

    *Agricultural use includes direct spreading or directing sludge to composting and methanization facilities. 

    Facilities concerned 

    Prefects are requested to issue orders requiring project owners and operators of urban or industrial wastewater treatment plants: 

    • with a treatment capacity greater than or equal to 10,000 population equivalents (PE); 
    • depending on the local context, wastewater treatment plants receiving effluents from industrial facilities in the textile and paper sectors, subject to authorization or registration under one of the following headings: 3610, 3620, 3630, 23xx, 2430, 2440, 2445, 

    a measurement campaign in sludge intended for agricultural use, focusing on the analysis of 52 PFAS substances (defined in Annex 1 of the circular). Measurements are carried out quarterly for 12 months. 

    The circular specifies that the measurement campaign will be extended to small wastewater treatment plants with a nominal treatment capacity of less than 10,000 PE during 2027. 

    Management of contaminated sludge 

    The circular also defines sludge management measures based on analysis results. 

    Exceeding a threshold stipulated by EC Regulation No. 2019/1021, known as the "POP Regulation" and recalled in Annex 2, must lead to the destruction of contaminated sludge by incineration. 

    Exceeding the thresholds for the 22 PFAS mentioned in Annex 3 must lead to: 

    • identifying and eliminating contamination sources,
    • directing sludge to compliant management channels,
    • conducting PFAS analyses in the soil of plots where sludge from the wastewater treatment plant has been spread over the past 5 years,
    • for operators of composting or methanization facilities: conducting analyses of digestates and composts.

    When other PFAS substances mentioned in Annex 1 are found in significant concentrations: 

    • Conduct an investigation into the causes of contamination, 
    • Adopt a similar sludge management framework. 

    Ministerial decrees will establish a lasting framework for sludge management starting from 2027. 

    New analyses for urban wastewater treatment plants 

    The decree of April 20, 2026 amends the decree of September 3, 2025 to complete the list of PFAS substances to be monitored in the influent and effluent waters of certain urban wastewater treatment plants. 

    As a reminder, the decree of September 3, 2025 requires a PFAS monitoring campaign to be carried out in the influent and effluent waters of urban wastewater treatment plants with a nominal treatment capacity greater than or equal to 10,000 PE, falling under IOTA category 2.1.1.0 "Collective wastewater treatment systems and non-collective sanitation facilities designed to collect and treat a gross organic pollution load". 

    Operators of these wastewater treatment plants must therefore add trifluoroacetic acid (TFA) to their PFAS monitoring campaign. 

    Furthermore, the deadline for carrying out the monitoring campaign, originally set for December 31, 2026, has been postponed to June 30, 2027.

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