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EPA Proposes to Scale Back TSCA PFAS Reporting Rule, Including New Exclusion for Imported Articles

The U.S. Environmental Protection Agency (EPA) is proposing revisions to the reporting rule for per- and polyfluoroalkyl substances (PFAS) under the Toxic Substances Control Act (TSCA). First promulgated in 2023, the PFAS...more

California Bans Ultraprocessed Foods in Schools

Key Takeaways - What happened: California enacted the first state ban on certain ultraprocessed foods (UPFs) in public school meals....more

EPA Proposes Changes to TSCA Risk Evaluation Framework Rule – Again

Summary The U.S. Environmental Protection Agency (EPA) published proposed revisions to the procedural framework rule for conducting risk evaluations under the Toxic Substances Control Act (TSCA) on September 23, 2025, 90 Fed....more

The Trump Administration’s First Unified Agenda for FDA Promises Major Changes for the GRAS Pathway, Food Ingredients, and...

The Make America Healthy Again (MAHA) program and implementation of the Modernization of Cosmetics Regulation Act of 2022 (MoCRA) will keep the U.S. Food and Drug Administration (FDA) hopping for at least the next year,...more

MAHA Commission Strategy Report Outlines Sweeping Federal Actions on Chemicals in Food and the Environment

Key Takeaways - What Happened: The Make America Healthy Again (MAHA) Commission has released its final Make Our Children Healthy Again Strategy report. The Strategy outlines extensive executive branch actions intended to...more

Exemptions Likely for the TSCA PFAS Reporting Rule

Now under review at the Office of Management and Budget (OMB) is a draft proposed rule that could dramatically reduce the scope of the Per- and Polyfluoroalkyl Substances (PFAS) Reporting Rule under Section 8(a)(7) of the...more

States Join FDA in the MAHA War on Food Ingredients

Food and food ingredient manufacturers take note: it’s not just the U.S. Food and Drug Administration (FDA) advancing “Make America Healthy Again” (MAHA) priorities. States are increasingly involved, as well. Several have...more

Leaked Draft of MAHA Commission Strategy Report Outlines Sweeping Federal Actions on Chemicals in Food and the Environment

Key Takeaways - What Happened: A leaked draft of the Make Our Children Healthy Again Strategy (the Make America Healthy Again (MAHA) Commission’s action plan) is circulating. The draft outlines extensive executive branch...more

Regulation of Advanced Recycling Is at a Crossroad

Under the Biden administration, the U.S. Environmental Protection Agency (EPA) dealt two substantial blows to efforts to turn waste plastics into useful products through advanced recycling techniques such as pyrolysis. Now,...more

Louisiana and Texas Pass Laws Requiring Warning Labels for Certain Food Ingredients

Key Takeaways - What happened: Two recently enacted laws in Louisiana and Texas will each require separate warning labels on the packaging of food sold in their state if the food contains any of 44 specific ingredients....more

FDA Seeks Public Comment on Post-Market Chemical Review Prioritization Method

Key Takeaways - What Happened: The U.S. Food and Drug Administration (FDA) released its draft post-market chemical review prioritization method for public comment. Public comments are due July 18, 2025....more

MAHA Assessment: What Food and Chemical Stakeholders Need to Know

When the Make America Healthy Again (MAHA) Commission unveiled its Make Our Children Healthy Again Assessment on May 22 (reissued May 28), it framed the document as a clarion call: U.S. regulators must combat childhood...more

FDA to Overhaul Post-Market Chemical Review Program for Food Chemicals

Key Takeaways - What Happened: The U.S. Food and Drug Administration (FDA) announced plans to update its food safety post-market chemical review program over the next few months to increase transparency and accelerate its...more

EPA’s Path Forward on TSCA Becomes Clearer

After a period of uncertainty, how the U.S. Environmental Protection Agency (EPA) plans to revise its implementation of the Toxic Substances Control Act (TSCA) during the second Trump administration is coming into focus...more

PFAS Reporting Rule Deadlines Extended – and More Changes to Come

The U.S. Environmental Protection Agency (EPA) published an interim final rule on May 13, 2025, extending the reporting deadlines for its Per- and polyfluoroalkyl substances (PFAS) Reporting Rule, 40 C.F.R. Part 705, which...more

FDA Food Chemical Regulation: Understanding Pesticide Action Levels

The U.S. Food and Drug Administration’s (FDA) March 2025 publication of its new “Chemical Contaminants Transparency Tool” spotlighted a lesser-known aspect of FDA’s regulation of pesticide residues on food: action levels....more

EPA Administrator Zeldin Announces EPA’s PFAS Plan

On April 28, 2025, after much anticipation, U.S. Environmental Protection Agency (EPA) Administrator Lee Zeldin outlined the agency’s plans to address Per- and Polyfluoroalkyl Substances (PFAS). Although the announcement...more

FDA Food Chemical Regulation After the MAHA Executive Order

Just before the change in administration, the Food and Drug Administration (FDA) made headlines by revoking approvals to use the color additive FD&C Red Dye No. 3 in food after January 15, 2027. This was the latest example of...more

EPA Announces Reevaluation of the TSCA Risk Evaluation Framework Rule (Updated)

This alert was originally published on March 20, 2025, and has been revised based on recent developments. Last year, the U.S. Environmental Protection Agency (EPA) under the Biden administration finalized amendments to...more

Twelve TSCA Developments to Expect in 2025 (Updated)

This alert was originally published on December 4, 2024, and has been revised based on recent developments. With the election of Donald Trump, the implementation of the Toxic Substances Control Act (TSCA) in 2025 will...more

EPA Announces Reevaluation of the TSCA Risk Evaluation Framework Rule

Last year, the U.S. Environmental Protection Agency (EPA) under the Biden administration finalized amendments to the procedural framework rule for conducting risk evaluations under the Toxic Substances Control Act (TSCA) that...more

GRAS Self-Affirmation for Food Ingredients – To Be or Not to Be?

Key Takeaways - What Happened: HHS Secretary Kennedy directed FDA to consider removing the current self-affirmation pathway for determining that a food ingredient is Generally Recognized as Safe (GRAS)....more

RMP Rulemaking Redux

The U.S. Environmental Protection Agency’s (EPA) Risk Management Program (RMP) regulations, 40 C.F.R. Part 68, appear to be headed back to rulemaking. These much-debated provisions have been amended, rescinded, and...more

EPA Finalizes TSCA Risk Management Rules for PCE and TCE (Updated)

Two more chlorinated solvents have been wholly or partially banned by the U.S. Environmental Protection Agency (EPA) under the Toxic Substances Control Act (TSCA). Following the May 8, 2024 final rule on methylene chloride,...more

Outlook for Trump Administration Environment, Energy, and Natural Resource Regulation, Enforcement & Litigation

Overview - Following our post-election Alert outlining major anticipated themes for environmental and natural resource law and policy in the second Trump administration, leaders from a number of our practices – many of...more

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