New Framework for Monitoring PFAS in Wastewater Treatment Plants

A new circular and a decree issued in April 2026 strictly regulate the monitoring and management of PFAS in sewage sludge from wastewater treatment plants (WWTPs) intended for agricultural use and expand the testing for TFA in wastewater

Juliette Virly
EHS Consultant
Publication: 
17.06.2026
Contents
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🔎 Things to remember

  • Mandatory Monitoring Campaign: Wastewater treatment plants (WWTPs) with a capacity of more than 10,000 population equivalents (PE), as well as those associated with the textile and paper industries, must analyze 52 PFAS substances quarterly for 12 months in their sludge intended for agricultural use (land application, composting, anaerobic digestion).
  • Future Expansion and Sustainability: This monitoring requirement will be extended to “small” wastewater treatment plants (fewer than 10,000 PE) in 2027, when ministerial decrees will establish a framework for sustainable management.
  • Strict Management of Contaminated Sludge: If regulatory thresholds are exceeded (POP regulations or the list of 22 PFAS), operators must destroy the sludge by incineration, identify the sources of contamination, and analyze the soil on agricultural plots that have received sludge over the past 5 years.
  • Addition of TFA and Extension of Deadline: For influent and effluent from municipal wastewater treatment plants,trifluoroacetic acid (TFA) must be added to the list of PFAS to be monitored. In exchange, the deadline for conducting this water monitoring campaign has been extended to June 30, 2027 (instead of the end of 2026).

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    As a reminder, the interministerial action plan on PFAS, launched in 2024, aims to reduce the exposure of the population and the environment to PFAS substances. In particular, it includes a measure to characterize PFAS levels in fertilizers, including sludge from wastewater treatment plants. 

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

    *Agricultural utilization includes direct application or directing the sludge to composting and anaerobic digestion facilities. 

    The facilities in question 

    Prefects are required to issue an order requiring the owners and operators of municipal or industrial wastewater treatment plants to: 

    • with a treatment capacity of 10,000 population equivalents (PE) or more; 
    • Depending on the local context, wastewater treatment plants receiving effluent from industrial facilities in the textile and paper sectors that are subject to authorization or registration under one of the following codes: 3610, 3620, 3630, 23xx, 2430, 2440, 2445, 

    A campaign to measure levels of 52 PFAS substances (defined in Annex 1 of the circular) in sludge intended for agricultural reuse. The measurements are taken quarterly over a 12-month period. 

    The circular specifies that the monitoring campaign will be expanded to include small wastewater treatment plants with a nominal treatment capacity of less than 10,000 PE in 2027. 

    Contaminated Sludge Management 

    The circular also outlines sludge management measures based on the results of the analyses. 

    Exceeding a threshold specified in EC Regulation No. 2019/1021, known as the “POP Regulation” and referenced in Annex 2, must result in the destruction of the contaminated sludge by incineration. 

    Exceeding the thresholds for the 22 PFAS listed in Annex 3 must result in: 

    • identify sources of contamination in order to eliminate them,
    • direct the sludge to appropriate management channels,
    • conduct PFAS analyses of soil samples from plots where sewage sludge from the wastewater treatment plant has been applied over the past 5 years,
    • For operators of composting or anaerobic digestion facilities: conduct analyses of digestate and compost.

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

    • Investigate the causes of contamination, 
    • Adopt a similar sludge management framework. 

    Ministerial decrees will establish a long-term framework for sludge management starting in 2027. 

    New Testing Methods for Municipal Wastewater Treatment Plants 

    The decree of April 20, 2026, amends the decree of September 3, 2025, to expand the list of PFAS substances that must be monitored in the inflow and outflow waters of certain municipal wastewater treatment plants. 

    As a reminder, the decree of September 3, 2025, requires the implementation of a PFAS monitoring program in the influent and effluent of urban wastewater treatment plants with a nominal treatment capacity of 10,000 PE or more, as defined in IOTA section 2.1.1.0 "Public wastewater treatment systems and on-site wastewater treatment systems designed to collect and treat a gross organic pollution load." 

    Operators of these wastewater treatment plants must therefore include trifluoroacetic acid (TFA) in their PFAS monitoring program. 

    In addition, the deadline for completing the monitoring campaign, originally set for December 31, 2026, has been extended to June 30, 2027.

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