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New Mexico Legislature Requests Reevaluation of Key Exemption from PFAS Product Sales Ban Statute

As we’ve discussed in a prior post, among states that have enacted statutory restrictions on sales of products containing intentionally added PFAS, New Mexico has been unique in crafting an exemption for fluoropolymers, which...more

New Jersey Enacts PFAS-in-Products Statute with Category-Based Sales Ban, Labeling for Cookware, and Funding of Source Reduction...

On January 12, 2026, before leaving office, New Jersey Governor Phil Murphy signed S.B. 1042, the “Protecting Against Forever Chemicals Act,” into law, thus adding the Garden State to the list of states that have enacted...more

Ringing in 2026 with a Look at Newly Effective State Regulation of PFAS in Products

January 1, 2026 was the effective date for a number of state law provisions relating to intentionally added PFAS in certain categories of products. July 1, 2026 will be the effective date for several more. As we have...more

PFAS Product Labeling Requirements Set to Take Effect in Connecticut and New Mexico in the Coming Months

Both Connecticut and New Mexico are moving forward with regulations to implement statutory labeling requirements for products in certain categories that contain intentionally added PFAS. Connecticut’s labeling requirement...more

EPA Proposes Significant Changes to the TSCA PFAS Reporting RuleThat Would Expand Exemptions

As foreshadowed in EPA’s most recent Unified Agenda, EPA has proposed to add four significant categories of exemptions to the TSCA PFAS Reporting Rule (Rule), citing burdensomeness of the existing Rule. Under the Proposed...more

Maine DEP Issues Initial Currently Unavoidable Use Determinations for PFAS-Containing Products Subject to Impending Sales...

Updating our earlier post from March 2025, Maine has completed a regulatory process and has adopted updates to its PFAS in products rules to identify two approved Currently Unavoidable Use (CUU) exemptions from the state’s...more

Minnesota’s Proposed PFAS Reporting Rules Are Disapproved for Procedural and Substantive Deficiencies

We’ve been following Minnesota’s proposed PFAS-in-products reporting rules for the past several months. As part of the rulemaking process under the Minnesota Administrative Procedures Act, and following public comment and a...more

UPDATE: Minnesota Announces 6-Month Extension of PFAS-in-Products Reporting Deadline, to July 1, 2026

Updating our recent post, the Minnesota Pollution Control Agency (MPCA) has now clarified its recent statement, following significant public comment, that it would exercise its statutory authority to extend the compliance...more

Minnesota Extends Its PFAS-in-Products Reporting Deadline After Significant Public Comments

After evaluating public comments on its proposed PFAS-in-products reporting rules, the Minnesota Pollution Control Agency (MPCA) has agreed to exercise its authority under section 116.943 of the Minnesota Statutes (Amara’s...more

Minnesota Will Continue to Receive Public Comments on Proposed New Rules on PFAS in Products Reporting

Minnesota’s Pollution Control Agency (MPCA) held a public hearing on May 22, 2025 concerning its proposed rules that would implement PFAS-in-products reporting requirements and associated fees on entities covered by Amara’s...more

New Mexico Enacts Sweeping Statute Phasing in Restrictions on PFAS in Products, Contemplating “Currently Unavoidable Use”...

In early April 2025, New Mexico enacted a statute restricting intentionally added PFAS in products, similar in scope to Maine’s and Minnesota’s existing laws. The New Mexico statute imposes a ban on sales and distribution...more

Maine’s Draft Proposed Rule on PFAS “Currently Unavoidable Use” Determinations

Maine recently published proposed rules (PDF link) aimed at implementation of its existing statute (which we’ve discussed here, here and here) limiting the sale and distribution within the state of products containing...more

Minnesota Seeks Comment on Rules Implementing Reporting Requirement for Products Containing Intentionally Added PFAS and...

Following up on the rulemaking process presaged by Minnesota’s comprehensive statute (Amara’s Law) requiring phase outs of PFAS intentionally added to products, which we’ve previously discussed here and here, the Minnesota...more

Rhode Island Enacts Statutory Ban on Consumer Products and Firefighting Foams with Intentionally Added PFAS

In late June 2024, Rhode Island joined the growing list of states that have enacted phased bans on the manufacture, sale, and distribution of various types of products containing PFAS. Rhode Island’s statute, entitled the...more

Maine Again Amends PFAS Ban Statute – More Product Categories Get Specific Dates, Reporting Requirements Are Narrowed

Maine has once again amended and clarified its statutory restrictions on the sale of numerous categories of PFAS-containing products. The net effect of the legislation, enacted on April 16, 2024, is to 1) limit the scope and...more

Maine and Minnesota Accepting Proposals Through March 1, 2024 for “Currently Unavoidable Use” Exemptions from Upcoming State Ban...

By statutory enactment, Maine intends to ban the sale, marketing, and distribution of products or product components containing intentionally added PFAS, effective January 1, 2030. 38 M.R.S. § 1614. This follows Maine’s...more

NJDEP Issues Guidance for Green, Sustainable, and Resilient Remediation

In September, NJDEP’s Contaminated Site Remediation and Redevelopment program (CSRR) issued new guidance (the Administrative Guidance for Green, Sustainable, and Resilient Remediation) encouraging the use of green and...more

Minnesota Statute Takes a Robust Approach to PFAS Regulation, Including Reporting Requirements for Manufacturers and a Sales Ban

On May 24, 2023, Minnesota’s Governor signed into law a sweeping set of statutory provisions concerning the handling and sale of PFAS-containing products within Minnesota. Among other things, the statute sets a ban on various...more

Maine Presses Pause on PFAS Reporting Requirements

We reported previously on Maine’s 2021 law barring the sale of new products containing intentionally added PFAS and the reporting requirements that the law imposed upon manufacturers. Under the law, both the first phase of...more

Michigan Court Rules State PFAS Drinking Water Regulations Lacked Adequate Consideration of Costs, with Implications for...

On November 15, 2022, in response to a challenge by 3M, the Michigan Court of Claims invalidated the drinking water MCLs and attendant groundwater standards for several PFAS substances, including PFOA (8 parts per trillion,...more

California, Maine Take Similar but Different Approaches in Limiting Sales of Products Containing Intentionally-Added PFAS

More and more states are passing statutes to restrict and/or monitor sales of products containing PFAS. Recent news out of Maine suggests some practical downsides to a more aggressive legislative scheme; last month...more

State Enforcement Against the Federal Government, Part 2

Almost two years ago, we posted on the civil settlement of a dispute between the New Mexico Environment Department (NMED) and the U.S. Department of Defense (DoD) over a state-level enforcement action against Cannon Air Force...more

ESG Essentials: What You Need To Know Now - Episode 10 - Recycling Your Way to ESG Success [Audio]

Our ESG podcast series features short episodes covering core ESG concepts. Each podcast explores important issues for businesses that are concerned with developing and deploying an ESG profile, responding to increased...more

EPA Announces Funding for Disadvantaged Communities to Address PFAS in Drinking Water, Synthesizing Approaches to PFAS and...

Alongside USEPA’s recent issuance of new Health Advisory Levels, or HALs, for certain PFAS chemicals (namely, PFOA, PFOS, PFBS, and GenX), the Agency also announced that, as part of the Biden Administration’s...more

ESG Essentials: What You Need To Know Now - Episode 8 - Environmental Justice [Audio]

Our ESG podcast series features short episodes covering core ESG concepts. Each podcast explores important issues for businesses that are concerned with developing and deploying an ESG profile, responding to increased...more

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