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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

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

New Mexico Poised to Be First Jurisdiction to Impose Labeling Requirements on All Products Containing PFAS

During a recent webinar, the New Mexico Environment Department (NMED) announced plans to propose a rule that will impose an unprecedented labeling requirements on all products containing intentionally added per- and...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

Precedent to Be Set for State PFAS in Products Laws as Maine Proposes Currently Unavoidable Use Determinations for Certain...

Three U.S. states – Maine, Minnesota, and New Mexico – have laws restricting intentionally added per- and polyfluoroalkyl substances (PFAS) in all products under various compliance deadlines. In each of these laws, the...more

Deadline Extended for Reporting PFAS in Products in Minnesota, Proposed Minnesota PFAS Reporting Rule under Administrative Review

Under Minnesota’s PFAS in products law, manufacturers of products containing intentionally added per- and polyfluoroalkyl substances (PFAS) must report those products to the Minnesota Pollution Control Agency (MPCA) by...more

California Proposes Listing Microplastics Under Safer Consumer Products Program

The California Department of Toxic Substances Control (DTSC) has taken a step toward regulating microplastics. On June 20, 2025, DTSC proposed to add microplastics to its Candidate Chemical List (CCL) under the state’s Safer...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

Minnesota Pollution Control Agency Releases Proposed Reporting Rule for PFAS in Products

The Minnesota Pollution Control Agency (MPCA) is seeking comment on a first-of-its-kind proposed rule that will require manufacturers of products containing intentionally added per- and polyfluoroalkyl substances (PFAS) to...more

New Mexico Becomes Third U.S. State to Prohibit PFAS in Products

This alert was originally published on March 25, 2025, and has been revised based on recent developments. In 2021, Maine became the first U.S. state to enact a law imposing reporting requirements and material...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

New Mexico Poised to Become Third U.S. State to Prohibit PFAS in Products

In 2021, Maine became the first U.S. state to enact a law imposing reporting requirements and material restrictions on all products containing intentionally added perfluoroalkyl and polyfluoroalkyl substances (PFAS)....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

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

TSCA Confidentiality Protections Upheld by D.C. Circuit Court

In a landmark decision, the D.C. Circuit Court invalidated an aspect of a U.S. Environmental Protection Agency (EPA) rule concerning confidential business information (CBI) under the Toxic Substances Control Act (TSCA). The...more

TSCA Fee Payments for Manufacturers of Five High-Priority Substances

Companies that manufacture any of five chemicals are facing substantial fee payments under the Toxic Substances Control Act. The U.S. Environmental Protection Agency (EPA) has published preliminary lists of manufacturers that...more

EPA Finalizes Workplace Control Requirements for Carbon Tetrachloride

The U.S. Environmental Protection Agency (EPA) has finalized a rule to protect workers from exposure to carbon tetrachloride (CTC), 40 C.F.R Part 751, Subpart H. This final rule, published on December 18, 2024, aligns with...more

Updates to New Chemicals Regulations under the Toxic Substances Control Act

Key Takeaways Delays by the U.S. Environmental Protection Agency (EPA) in processing premanufacture notices (PMNs) under the Toxic Substances Control Act (TSCA) may lessen under final amendments to section 5 published on...more

EPA Finalizes TSCA Risk Management Rules for PCE and TCE

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

Twelve TSCA Developments to Expect in 2025

With the election of Donald Trump, the implementation of the Toxic Substances Control Act (TSCA) in 2025 will differ significantly from the pre-election expectations. Here are our projections on the likely developments in the...more

EPA Finalizes Revisions to PBT Rules for DecaBDE and PIP (3:1)

Key Takeaways - The U.S. Environmental Protection Agency (EPA) published a final rule revising the regulations for decabromodiphenyl ether (decaBDE) and phenol, isopropylated phosphate (3:1) (PIP (3:1)) on November 19,...more

2024 Chemical Data Reporting Deadline Extended by EPA

The U.S. Environmental Protecting Agency (EPA) is amending the Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) regulations to extend the September 30, 2024 submission deadline for 2024 reports to November...more

EPA Announces 8-Month Delay in Submission Window for TSCA PFAS Reporting Rule

The U.S. Environmental Protection Agency (EPA) is modifying the Toxic Substances Control Act (TSCA) regulation imposing reporting and recordkeeping requirements for perfluoroalkyl and polyfluoroalkyl substances (the Rule) to...more

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