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Pending Legislation May Expand PFAS Regulatory Framework for Michigan Municipalities

By: Sinéad Redmond (Senior Associate, Municipal Law and Government Relations Practice Group)

05/07/26

The Michigan Legislature is currently considering legislation that would directly affect municipally operated wastewater treatment plants and expand local coordination obligations. In April 2026, Michigan legislators introduced a package of nine bills aimed at strengthening statewide regulation of per- and polyfluoroalkyl substances (“PFAS”), which are commonly referred to as “forever chemicals.” If enacted, this legislative package would expand Michigan’s PFAS regulatory framework on multiple fronts.

Of particular relevance to municipalities, the proposed testing requirements for sewage sludge and its derivatives would directly affect entities that operate wastewater treatment plants. Municipal utilities may face new sampling, reporting, and compliance obligations tied to PFAS content in sewage sludge and derivatives. Other proposed measures include restricting PFAS use in certain consumer products; expanding EGLE’s authority to investigate contamination and notify affected residents; codifying the Michigan PFAS Action Response Team; and creating new legal and regulatory mechanisms to address PFAS contamination and hold PFAS users and manufacturers liable for cleanup and associated harms.

Although the bills primarily target manufacturers and product suppliers, municipalities are likely to experience both indirect and, in some cases, direct impacts. In addition to the wastewater treatment obligations, EGLE’s increased role will likely require coordination with municipalities on contamination investigation and response. More generally, the legislation reflects an effort to incorporate existing institutional structures into the PFAS regulatory framework, highlighting the value of proactive planning and intergovernmental coordination.

At this stage, the bills have been introduced and referred to committee, and their final scope remains uncertain. Bodman will continue to monitor the legislation and will issue further updates as needed.

Please contact the author, Sinéad Redmond (734-930-2202 | sredmond@bodmanlaw.com) or any member of Bodman’s Municipal Law and Government Relations Practice Group or Environmental Practice Group if you have questions regarding this matter or other legal matters facing your municipal government. Bodman cannot respond to your questions or receive information from you without establishing an attorney-client relationship and clearing potential conflicts with other clients. Thank you for your patience and understanding.

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