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EPA Issues Second Extension of PFAS Reporting Timeline Under TSCA Section 8(a)(7)

On May 12, 2025, EPA announced that it will again revise the reporting timeline for manufacturers of per- and polyfluoroalkyl substances (PFAS) under Section 8(a)(7) of the Toxic Substances Control Act (TSCA). The data...more

3M Agrees to Enter into Settlement with State of New Jersey and Pay up to $450 Million to Resolve Present and Future PFAS...

On May 12, 2025, 3M announced an agreement with the State of New Jersey to resolve two sets of legal liabilities related to PFAS contamination: (1) all claims that the company is currently facing or has faced related to PFAS...more

EPA’s PFAS Strategy Evolves Amid Continued Regulatory, Legislative, and Litigation Uncertainty

While the Trump administration’s PFAS policy framework is beginning to take shape, uncertainties remain across the regulatory, litigation and legislative fronts. On April 28, EPA Administrator Lee Zeldin announced a set of...more

PFAS, HFCs and Related Chemicals in the Data Center Industry

Data centers use various chemicals that have recently been the focus of regulatory efforts at the federal and state level. The historic or future use of these chemicals may create liabilities, obligations, or new costs for...more

White House Directs Modernization of NEPA Permitting to Accelerate Environmental Reviews

The Trump administration’s directive instructs the Council on Environmental Quality to implement technological reforms and establish a unified federal system to conduct environmental reviews and evaluate permits....more

Presidential Memo Directs Immediate Repeal of Regulations Without Public Notice and Comment

Continuing with the Trump administration’s deregulatory agenda, the White House issued a Presidential Memorandum on April 9 titled Directing the Appeal of Unlawful Regulations. It instructs executive agencies to repeal...more

Wisconsin Budget Debate Rekindles Battle Over State PFAS Liability Exemptions

The question is not whether Wisconsin will act on PFAS—but who should pay the bill. As Wisconsin Governor Tony Evers rolls out a sweeping plan to tackle per- and polyfluoroalkyl substances (PFAS) contamination statewide,...more

The Latest on PFAS: What Policyholders Need to Know Now

We have previously written on the evolving risks associated with PFAS—also known as “forever chemicals”—and their implications for policyholders navigating environmental liabilities involving both PFAS and PFAS-related...more

Court Grants Additional 30-Day Pause in PFAS Drinking Water Rule Litigation

On April 10, 2025, at the request of the Environmental Protection Agency (EPA), the U.S. Court of Appeals for the District of Columbia Circuit extended the stay by 30 days in American Water Works Association, et al. v. EPA,...more

Congressional Allocation Signifies EPA Intent to Maintain the One-Time PFAS Reporting Rule Under TSCA Section 8(a)(7)

Recently, Congress allocated approximately $17 million in EPA’s fiscal year 2025 budget to modernize outdated technical systems and accelerate chemical reviews which may help resolve ongoing concerns about the functionality...more

House Republicans Seek to Rescind Late-Term EPA Rule Curtailing PFAS Exemptions for New Chemicals

House Republicans have introduced a joint resolution under the Congressional Review Act (CRA) to nullify a rule issued by the Environmental Protection Agency (EPA) late in the prior administration. The rule narrowed the...more

EPA Signals Potential PFAS Policy Pivot Under New Administrator

In March, EPA Administrator Lee Zeldin addressed top state environmental officials, highlighting the Agency’s priorities for the year ahead. Without committing the EPA to an official stance, Zeldin reaffirmed his commitment...more

Trump Launches $1 Billion Plus Investment Fast Track with New Executive Order

The new federal office aims to accelerate mega-investments and revamp CHIPS Act oversight. Against the backdrop of rising global competition and ongoing industrial policy debates, on March 31, 2025, President Trump...more

Maryland Files PFAS Suit Against Downstream Manufacturer

Maryland has filed suit against W.L. Gore & Associates (Gore), a downstream user of PFAS-containing materials, alleging that its manufacturing processes contributed to PFAS contamination through its use of...more

Court Approves 60-Day Stays in Legal Battles over Biden-Era PFAS Regulations amid Administration Shift

In a move that signals potential policy shifts under the new administration, the U.S. Court of Appeals for the District of Columbia Circuit granted EPA’s requests for 60-day stays in two high-profile cases challenging...more

New ASTM Standard Aims to Facilitate Assessing Climate Risk and Resilience Considerations

Owners, lenders and investors in real property have long relied on ASTM E 1527-21, a product of ASTM International, in connection with Phase I Environmental Site Assessments. This product is used to establish that “all...more

New York and California’s Restrictions on PFAS in Apparel Takes Effect

New York and California have recently imposed sweeping prohibitions on the sale of apparel containing per- and polyfluoroalkyl substances (PFAS). These prohibitions have a broad scope and are effective and enforceable as of...more

Uncertain Times Ahead for EPA Regulation of PFAS

With 2024 winding down and a change of presidential administration imminent, it is worthwhile to consider the state of EPA’s efforts to regulate per- and polyfluoroalkyl substances (PFAS). In this connection, EPA recently...more

PFAS in Fire Protection Products Continues to Generate Litigation, Liability

Litigation risks associated with per and polyfluoroalkyl substances (PFAS) continue to grow, as demonstrated by settlements over the last year in the set of claims being adjudicated in a multidistrict litigation (MDL-2873) in...more

New Lawsuit Highlights PFAS Exposure for Fertilizer Manufacturers

A lawsuit filed earlier this year highlights potential PFAS liability exposure for fertilizer manufacturers, especially those that produce biosolid-based products. Five Texas farmers have sued Synagro Technologies, alleging...more

Bipartisan Legislation Presents Opportunity for Passing PFAS Laws

On September 19, the Senate Armed Services Chairman released the final Manager’s Amendment for the National Defense Authorization Act (NDAA)—signaling that it is now time for the House and Senate to negotiate this “must-pass”...more

EPA Issues Proposed Rule Adding New PFAS to the Toxics Release Inventory (TRI)

On October 1, 2024, the U.S. Environmental Protection Agency (EPA) proposed to add 16 individual per- and polyfluoroalkyl substances (PFAS) as well as 15 PFAS categories, representing over 100 PFAS to the Toxics Release...more

EPA Gathering Information for Another Possible TSCA Section 6 Rulemaking

On September 30, 2024, the U.S. Environmental Protection Agency (EPA) issued a notice seeking comment on the manufacture of certain per- and polyfluoroalkyl substances (PFAS) during the fluorination of high-density...more

EPA Issues Eight-Month Delay of the Reporting Period for the PFAS Reporting Rule under TSCA Section 8(a)(7)

On September 5, the U.S. Environmental Protection Agency (EPA) cut industry a significant break by postponing the reporting period for the one-time reporting rule for per- and polyfluoroalkyl substances (PFAS) under Section...more

The End of Chevron Deference Could Spell Trouble for EPA’s PFAS “Hazardous Substance” Rule

A recent Supreme Court ruling could further jeopardize EPA’s PFAS hazardous substance designation, as the agency is attempting to advance a novel use of delegated legislative authority to further regulate PFAS chemicals....more

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