Hot Topics in International Trade-The Mod Act
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FDA Releases Guidance for Voluntary Qualified Importer Program - The U.S. Food and Drug Administration (FDA) has released guidance with revisions to the Food Safety Modernization Act Voluntary Qualified Importer Program...more
In September 2024, the Environmental Protection Agency ("EPA") announced an extension to the reporting period for its new Per- and Polyfluoroalkyl Substances ("PFAS") reporting and recordkeeping requirements under the Toxic...more
The U.S. Environmental Protection Agency (EPA) published a far-reaching and important final rule (Rule) on Oct. 11, 2023, requiring comprehensive reporting of per- and polyfluoroalkyl substances (PFAS) manufactured and...more
With the completion of the voluntary phaseout of one form of short-chain per- and polyfluoroalkyl substances (PFAS) as a grease-proofing agent, the U.S. Food and Drug Administration (FDA) has rejected the view that...more
With Assembly Bill A3556C, New York joins a growing list of states considering or enacting broad bans on the sale and distribution of products containing per- and polyfluoroalkyl substances ("PFAS")....more
In 2023, the United States Environmental Protection Agency (“EPA”) issued a final rule under the Toxic Substances Control Act (“TSCA”) which requires manufacturers, including importers, of certain per- and polyfluoroalkyl...more
The United States Environmental Protection Agency (“EPA”) started the new year by finalizing two rules involving per- or polyfluoroalkyl substances (“PFAS”) under the Toxic Substances Control Act (“TSCA”) and the Toxic...more
The Situation: In 2019, Congress amended the Toxic Substances Control Act ("TSCA") to require the Environmental Protection Agency ("EPA") to promulgate a reporting rule on per- and polyfluoroalkyl substances ("PFAS"). EPA...more
On October 11, 2023, the U.S. Environmental Protection Agency (EPA) published a final rule under the Toxic Substances Control Act (TSCA) Section 8(a)(7), requiring manufacturers to submit a one-time report to the Agency...more
The U.S. Environmental Protection Agency (EPA) published a far-reaching and enormously important final rule (Rule) on Oct. 11, 2023, requiring comprehensive reporting of per- and polyfluoroalkyl substances (PFAS) manufactured...more
On February 14, 2023, the Maine Department of Environmental Protection (MDEP) issued a proposed draft rule that provides guidance on reporting requirements and sales prohibitions for products and product components containing...more
Multiple states have enacted laws that impose prohibitions or notification obligations on the commercial distribution of PFAS-containing products, with requirements under the laws of three states (California, Maine and New...more
Did you manufacture or import a water repellant t-shirt or a nonstick cooking pan or high performance mountain wear in the past ten years? If so, you could be required to provide ten years of past data and details regarding...more
On June 28, 2021, the U.S. Environmental Protection Agency (“EPA”) published a proposed rule that would require a one-time report from companies that manufactured or imported per- and polyfluoroalkyl substances (PFAS) in any...more
Do any of the articles, or article components, that your company imports contain PFAS? If so, your company may become subject to extensive reporting requirements proposed by EPA under the Toxic Substances Control Act (TSCA)....more
The Environmental Protection Agency (“EPA”) has announced it is taking three actions with respect to per- and polyfluoroalkyl substances (“PFAS”) under the Toxic Substances Control Act (“TSCA”): (1) proposing a rule that is...more