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PFAS in Cosmetics: State-Led Regulatory Surge Demands Proactive Compliance

States are rapidly enacting and implementing bans and reporting requirements for per- and polyfluoroalkyl substances (PFAS) in cosmetics, creating a complex and evolving compliance environment for manufacturers, distributors,...more

EPA Takes Action Against Inhance Technologies LLC on Fluorinated HDPE Containers

Since publishing an alert on U.S. Food and Drug Administration (FDA) efforts surrounding per- and polyfluoroalkyl substances (PFAS) in food packaging, Holland & Knight has monitored developments related to fluorinated and...more

Proposed Regulations that Impact Environmental Enforcement Aim to Clarify 2017 Tax Act

The Tax Cuts and Jobs Act (TCJA) of 2017, P.L. 115-97 (Dec. 22, 2017), made changes to the long-standing rule precluding deductibility of "any fine or similar penalty paid to a government for the violation of any law." ...more

MassDEP Seeks to Impose Its PFAS Monitoring Requirements in NPDES Permits

On July 14, 2020, the Massachusetts Department of Environmental Protection (MassDEP) issued a public notice regarding Shire Human Genetic Therapies' Cambridge facility's pollutant discharges to the Alewife Brook, along with a...more

House Committee to Review EPA’s Enforcement Activities

On Feb. 26, 2019, the House Committee on Energy and Commerce, Subcommittee on Oversight and Investigations will hold a hearing entitled "EPA's Enforcement Program: Taking the Environmental Cop Off the Beat." According to the...more

DOJ Issues More Guidance Impacting Environmental Enforcement

On Nov. 8, 2018, the Department of Justice (DOJ) Office of Public Affairs issued a press release indicating that then-Attorney General Jeff Sessions signed a memorandum (presumably before resigning) the day before that...more

Tax Changes Impacting Government Enforcement: Comments Due November 13, 2018

As described in a blog post on March 13, 2018, Section 13306 Tax Cuts and Jobs Act, P.L. 115-97 (Dec. 22, 2017) revises the longstanding rule on the deductibility as a business expense (or lack thereof) of "any fine or...more

EPA’s OIG Investigates Enforcement of the Lead-Based Paint Renovation, Repair and Painting Rule

On March 28, 2018, the Office of the Inspector General (OIG) of the U.S. Environmental Protection Agency (EPA) issued a Project Notification indicating its plans to begin preliminary research to evaluate the EPA’s...more

Recent Changes Expected to Impact Environmental Enforcement

• Two recent developments have the potential to significantly impact governmental enforcement actions under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, or Superfund), the Clean Water Act...more

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