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
8/12/2025
/ Cosmetics ,
Distributors ,
Enforcement Actions ,
Hazardous Substances ,
Importers ,
Manufacturers ,
New Legislation ,
Personal Care Products ,
PFAS ,
Popular ,
Regulatory Requirements ,
Reporting Requirements ,
Retailers ,
State Attorneys General ,
State Bans ,
State Legislatures ,
Toxic Chemicals
Major trade associations and water systems filed suit to challenge the Biden-era U.S. Environmental Protection Agency's (EPA) National Primary Drinking Water Rule for six per- and polyfluoroalkyl substances (PFAS) under the...more
In recent months, in response to increased consumer interest, federal and state government officials have taken action to propose and adopt laws and regulations directed at promoting consumer transparency and encouraging...more
4/3/2025
/ Disclosure Requirements ,
Environmental Policies ,
Fashion Industry ,
Greenhouse Gas Emissions ,
Manufacturers ,
New Legislation ,
PFAS ,
Proposed Legislation ,
Regulatory Requirements ,
Sustainability ,
Textiles
Although the U.S. Environmental Protection Agency (EPA) proposed the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as the federal Superfund law (PFAS Designation Rule) in September...more
11/26/2024
/ ASTM ,
CERCLA ,
Contamination ,
Discharge of Pollutants ,
Due Diligence ,
Enforcement ,
Environmental Liability ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Environmental Site Assessment ,
EPCRA ,
Final Rules ,
Hazardous Substances ,
Natural Resources ,
PFAS ,
Settlement ,
Superfund ,
Toxic Chemicals
The U.S. Environmental Protection Agency (EPA) is proposing to add 16 new, individually listed per- and polyfluoroalkyl substances (PFAS) and 15 PFAS categories to the Toxics Release Inventory (TRI) list as "chemicals of...more
The U.S. Environmental Protection Agency (EPA) on Sept. 6, 2024, announced the availability of $6.5 billion in Water Infrastructure Finance and Innovation Act (WIFIA) funding and $1 billion in State Infrastructure Financing...more
9/20/2024
/ Critical Infrastructure Sectors ,
Domestic Corporations ,
Drinking Water ,
Environmental Protection Agency (EPA) ,
Federal Funding ,
Federal Loans ,
Financing ,
Infrastructure ,
Infrastructure Financing ,
Joint Venture ,
Partnerships ,
PFAS ,
Popular ,
Project Finance ,
State and Local Government ,
Tribal Lands ,
Trusts ,
Water ,
Water Supplies
While product importers were spending the summer poring over the Instructions for Reporting PFAS Under TSCA Section 8(a)(7) (May 2024), the U.S. Environmental Protection Agency (EPA) was working on a Direct Final Rule and...more
Just past the halfway point of 2024, it's already been a busy year for those following regulatory developments related to per- and polyfluoroalkyl substances (PFAS). Building on its plans in the 2021 PFAS Strategic Road Map...more
7/19/2024
/ CERCLA ,
Corrective Actions ,
Drinking Water ,
Environmental Protection Agency (EPA) ,
Final Rules ,
Hazardous Substances ,
Hazardous Waste ,
PFAS ,
RCRA ,
Safe Drinking Water Act ,
Toxic Chemicals ,
Toxic Substances Control Act (TSCA)
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
6/27/2024
/ Compliance ,
Data Collection ,
Environmental Protection Agency (EPA) ,
Filing Deadlines ,
Final Rules ,
Hazardous Substances ,
Importers ,
Imports ,
NDAA ,
PFAS ,
Recordkeeping Requirements ,
Reporting Requirements ,
Supply Chain ,
Toxic Chemicals ,
Toxic Substances Control Act (TSCA)
President Joe Biden signed the bipartisan, bicameral Federal Aviation Administration Reauthorization Act of 2024 into law on May 16, 2024, extending many old provisions as well as creating new policy. One new provision is...more
The U.S. Environmental Protection Agency (EPA) on April 19, 2024, announced its Final Rule designating two per- and polyfluoroalkyl substances (PFAS) compounds – perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid...more
4/29/2024
/ CERCLA ,
Compliance ,
Discharge of Pollutants ,
Drinking Water ,
Due Diligence ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Final Rules ,
Hazardous Substances ,
Manufacturers ,
PFAS ,
Regulatory Reform ,
Toxic Chemicals ,
Water Supplies
The U.S. Court of Appeals for the Fifth Circuit ruled on March 21, 2024, on a petition filed by Inhance Technologies LLC (Inhance) against the U.S. Environmental Protection Agency (EPA) in Inhance Technologies, L.L.C. v. U.S....more
The U.S. Environmental Protection Agency (EPA) issued a proposed rule on Sept. 6, 2022, to designate perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS), along with their structural isomers, as hazardous...more
4/5/2024
/ CERCLA ,
Clean Water Act ,
Congressional Committees ,
Congressional Investigations & Hearings ,
Contaminated Properties ,
Enforcement ,
Environmental Protection Agency (EPA) ,
Hazardous Substances ,
Hazardous Waste ,
Mitigation ,
PFAS ,
Proposed Rules ,
Public Health ,
Safe Drinking Water Act ,
Site Remediation ,
Wastewater
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
4/3/2024
/ FDCPA ,
Food and Drug Administration (FDA) ,
Food Manufacturers ,
Food Safety ,
Hazardous Substances ,
Importers ,
Imports ,
Inspections ,
PFAS ,
Product Packaging ,
Regulatory Requirements ,
Toxic Chemicals
The 1984 Hazardous and Solid Waste Amendments amended the Resource Conservation and Recovery Act (RCRA) to add the following sections requiring corrective action for releases of hazardous waste or hazardous constituents ...more
2024 is off to a busy start for folks following state laws related to per- and polyfluoroalkyl substances (PFAS) in products. Multiple states have passed legislation impacting product manufacturers and retailers. Maine and...more
2023 was a busy year for folks following legal developments related to per- and polyfluoroalkyl substances (PFAS). In December, the U.S. Environmental Protection Agency (EPA) issued its Second Annual Progress Report. Some of...more
1/18/2024
/ Air Quality Standards ,
Bodily Injury ,
CERCLA ,
Certifications ,
Compliance ,
Contamination ,
Discovery ,
Drinking Water ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Final Rules ,
Hazardous Substances ,
Manufacturers ,
Multidistrict Litigation ,
NDAA ,
PFAS ,
Popular ,
Proposed Rules ,
Reporting Requirements ,
Toxic Chemicals ,
Toxic Substances Control Act (TSCA) ,
Wastewater
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
The 2024 National Defense Authorization Act (NDAA) (H.R. 2670), which authorizes expenditures for the U.S. Department of Defense (DOD or Department), passed the House of Representatives on Dec. 14, 2023, and is headed to...more
12/20/2023
/ Contamination ,
Department of Defense (DOD) ,
Drinking Water ,
Federal Budget ,
Federal Pilot Programs ,
Health and Safety ,
Military Service Members ,
NDAA ,
Pending Legislation ,
PFAS ,
Reporting Requirements ,
Toxic Chemicals
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
10/20/2023
/ Compliance ,
Effective Date ,
Environmental Protection Agency (EPA) ,
Filing Deadlines ,
Final Rules ,
Hazardous Substances ,
Importers ,
Manufacturers ,
NDAA ,
PFAS ,
Reporting Requirements ,
Statute of Limitations ,
Toxic Chemicals ,
Toxic Substances Control Act (TSCA) ,
Waste Management
Odds are that businesses involved in any kind of manufacturing or sale of physical products will be impacted by developments in legislation or case law involving per- and polyfluoroalkyl substances (PFAS). How big of an...more
9/27/2023
/ Consumer Product Companies ,
Contamination ,
Drinking Water ,
Hazardous Substances ,
Infrastructure ,
Manufacturers ,
PFAS ,
Product Packaging ,
Public Health ,
Toxic Chemicals ,
Toxic Exposure ,
Transportation Industry ,
Utilities Sector
The U.S. Environmental Protection Agency (EPA) is not the only federal agency that regulates per- and polyfluoroalkyl substances (PFAS). And states aren't the only ones scrutinizing PFAS in food packaging products. PFAS,...more
9/13/2023
/ Comment Period ,
Federal Food Drug and Cosmetic Act (FFDCA) ,
Food and Drug Administration (FDA) ,
Food Safety ,
Interstate Commerce ,
Investigations ,
Manufacturers ,
Pesticides ,
PFAS ,
Preemption ,
Product Packaging ,
Toxic Chemicals
The U.S. Environmental Protection Agency (EPA) announced on July 25, 2023, a proposed rule, published in the Federal Register on Aug. 9, 2023, to update the Air Emissions Reporting Requirements (AERR) to collect certain...more
The U.S. Environmental Protection Agency (EPA) on July 27, 2023, published its Semiannual Regulatory Agenda, which is intended to update the public about the agency's plan to review, propose and issue regulations over the...more
8/3/2023
/ Clean Air Act ,
Clean Water Act ,
Comment Period ,
Environmental Protection Agency (EPA) ,
FIFRA ,
New Source Performance Standards (NSPS) ,
NPRM ,
PFAS ,
Proposed Regulation ,
RCRA ,
Recordkeeping Requirements ,
Regulatory Agenda ,
Safe Drinking Water Act ,
State Implementation Plans (SIPs) ,
Toxic Substances Control Act (TSCA)
Minnesota is competing with Maine to have the most rigorous regulations for per- and polyfluoroalkyl substances (PFAS). Minnesota Gov. Tim Walz signed HF 2310 into law on May 24, 2023. Similar to Maine's PFAS requirements,...more
7/28/2023
/ Amended Legislation ,
Certification Requirements ,
Compliance ,
Consumer Product Companies ,
Governor Walz ,
Hazardous Substances ,
Labeling ,
Manufacturers ,
PFAS ,
Product Labels ,
Product Packaging ,
Reporting Requirements ,
Supply Chain ,
Toxic Chemicals ,
Waste Management