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
California's Department of Toxic Substances Control (DTSC) has proposed listing microplastics on its "Candidate Chemicals List" under the Safer Consumer Products (SCP) Program, a regulatory framework designed to reduce toxic...more
7/17/2025
/ Comment Period ,
Consumer Protection Laws ,
Environmental Policies ,
Manufacturers ,
NPRM ,
Plastics ,
Public Comment ,
Regulatory Requirements ,
Safer Consumer Product Regulations ,
Supply Chain ,
Sustainability ,
Toxic Chemicals ,
Toxic Substances Control Act (TSCA)
The U.S. Environmental Protection Agency (EPA) under the second Trump Administration has begun to shift the Biden Administration's policies related to the review of existing chemicals under Section 6 of the Toxic Substances...more
5/30/2025
/ Biden Administration ,
Chemicals ,
Comment Period ,
Environmental Protection Agency (EPA) ,
Final Rules ,
Personal Protective Equipment ,
Regulatory Agencies ,
Regulatory Agenda ,
Risk Assessment ,
Risk Management ,
Toxic Chemicals ,
Toxic Substances Control Act (TSCA) ,
Trump Administration
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) concluded its risk evaluation of 1,4-Dioxane under the Toxic Substances Control Act (TSCA) and issued a Notice of Availability of its Final Supplement to the Risk Evaluation and...more
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)
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
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
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
Forever chemicals are about to be forever regulated. With the most recent ban on per- or polyfluoroalkyl substances (PFAS) in food packaging set to go in effect in Vermont on July 1, 2023, this Holland & Knight alert focuses...more
The U.S. Environmental Protection Agency (EPA) on April 12, 2023, released an Advance Notice of Proposed Rulemaking (ANPRM) seeking public input and data to assist in the consideration of potential development of future...more
The U.S. Environmental Protection Agency (EPA) on March 29, 2023, published in the Federal Register its long-awaited proposal to regulate per- and polyfluoroalkyl substances (PFAS) under the Safe Drinking Water Act (SDWA)...more
3/30/2023
/ Comment Period ,
Contamination ,
Drinking Water ,
Environmental Protection Agency (EPA) ,
Hazardous Substances ,
PFAS ,
Proposed Regulation ,
Public Health ,
Public Hearing ,
Safe Drinking Water Act ,
Toxic Chemicals ,
Toxic Exposure
The U.S. Environmental Protection Agency (EPA) in 2022 advanced many of its regulatory priorities laid out in its October 2021 PFAS Strategic Roadmap across multiple regulatory programs. Below are some of the highlights, many...more
1/10/2023
/ CERCLA ,
Corporate Counsel ,
Drinking Water ,
Enforcement ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Hazardous Substances ,
NPDES ,
PFAS ,
Safe Drinking Water Act ,
Toxic Chemicals ,
Toxic Substances Control Act (TSCA)
The U.S. Environmental Protection Agency (EPA) issued four lifetime health advisories1 for several per- and polyfluroroalkyl substances (PFAS) on June 15, 2022. Health advisories issued for two contaminants – perflurooctanoic...more
The U.S. Environmental Protection Agency (EPA) notified the fluorinated high-density polyethylene (HDPE) industry (manufacturers, processors, distributors, users and so-called disposers of fluorinated polyolefin containers)...more