On July 23, 2025, the Minnesota Pollution Control Agency (MPCA) announced that it will allow manufacturers an additional six months to report required PFAS information, extending the original January 1, 2026, deadline to July...more
7/28/2025
/ Consumer Product Companies ,
Environmental Protection Agency (EPA) ,
Filing Deadlines ,
Manufacturers ,
PFAS ,
Proposed Regulation ,
Public Comment ,
Reporting Requirements ,
State and Local Government ,
Supply Chain ,
Time Extensions ,
Toxic Chemicals
On May 14, 2025, the United States Environmental Protection Agency (“EPA”) announced that it will rescind the nationwide Maximum Contaminant Levels (“MCLs”) for certain per- and polyfluoroalkyl substances (“PFAS”) set by the...more
The United States Environmental Protection Agency (“EPA”) has announced it will again be extending the data submission period for the Toxic Substances Control Act (“TSCA”) Section 8(a)(7) reporting requirement for per- and...more
5/14/2025
/ Environmental Protection Agency (EPA) ,
Filing Deadlines ,
Interim Final Rules (IFR) ,
Manufacturers ,
PFAS ,
Portal ,
Reporting Requirements ,
Small Business ,
Time Extensions ,
Toxic Chemicals ,
Toxic Substances Control Act (TSCA)
On April 9, 2025, President Trump directed federal agencies to repeal certain categories of regulations in his memorandum entitled Directing the Repeal of Unlawful Regulations (“Memorandum”). In this Memorandum, President...more
5/12/2025
/ Administrative Procedure Act ,
Clean Air Act ,
Clean Water Act ,
Deregulation ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Loper Bright Enterprises v Raimondo ,
Ohio v Environmental Protection Agency ,
Presidential Memorandum ,
Regulatory Reform ,
Sackett v EPA ,
Trump Administration ,
Waters of the United States ,
West Virginia v EPA
On April 28, 2025, EPA Administrator Zeldin issued the Agency’s most comprehensive statement since Trump’s inauguration regarding how EPA plans to address PFAS compounds under a variety of ongoing regulatory programs (“EPA...more
5/5/2025
/ Clean Water Act ,
Drinking Water ,
Environmental Protection Agency (EPA) ,
Hazardous Substances ,
PFAS ,
Regulatory Agenda ,
Reporting Requirements ,
Risk Assessment ,
Rulemaking Process ,
Site Remediation ,
Toxic Substances Control Act (TSCA)
When evaluating legal risk relating to per- and polyfluoroalkyl substances (“PFAS”), most businesses typically consider wastewater, groundwater, or soil impacts, not air emissions. However, state and federal regulatory...more
Since January 20, 2025, the Trump Administration has implemented numerous changes to federal environmental justice (“EJ”) initiatives which are expected to result in reduced permitting and regulatory burdens. While the...more
3/14/2025
/ Clean Energy ,
Climate Change ,
Environmental Justice ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Executive Orders ,
Inflation Reduction Act (IRA) ,
NEPA ,
Regulatory Reform ,
State and Local Government ,
Trump Administration
The United States Environmental Protection Agency (“EPA”) has extended the public comment period for the Draft Sewage Sludge Risk Assessment for Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonic Acid (PFOS) (“Draft...more
On January 15, 2025, the United States Environmental Protection Agency (“EPA”) published its “Draft Sewage Sludge Risk Assessment for Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonic Acid (PFOS)” (“Draft Risk...more
2/19/2025
/ Agricultural Sector ,
CERCLA ,
Clean Water Act ,
Contaminated Properties ,
Contamination ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Hazardous Substances ,
Notice and Comment ,
PFAS ,
Public Health ,
Risk Assessment
In the absence of enforceable federal standards for per- and polyfluoroalkyl substances (“PFAS”) in soil, several states have started the process of regulating PFAS in soil themselves. These regulations have implications for...more
2/4/2025
/ Contamination ,
Due Diligence ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Environmental Site Assessment ,
Hazardous Substances ,
PFAS ,
Public Health ,
Regulatory Requirements ,
Remediation ,
Site Remediation ,
State and Local Government
Climate control technology is increasingly a focal part of modern society’s expectation to have sophisticated supply chains, particularly relating to perishable items such as pharmaceuticals, raw products, and food. ...more
2/4/2025
/ Climate Change ,
Environmental Protection Agency (EPA) ,
Environmental Social & Governance (ESG) ,
Food Manufacturers ,
Greenhouse Gas Emissions ,
HFC Emissions ,
Montreal Convention ,
Pharmaceutical Industry ,
Regulatory Requirements ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Supply Chain ,
Sustainability
On November 14, 2024, the U.S. Environmental Protection Agency (“EPA”) determined that 1,4-dioxane presents an unreasonable risk of injury to human health under its conditions of use....more
In the absence of federal cleanup standards for per- and polyfluoroalkyl substances (“PFAS”) in groundwater, several states have started the process of regulating PFAS in groundwater themselves. As a result, states have...more
11/27/2024
/ Contamination ,
Discharge of Pollutants ,
Drinking Water ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Groundwater ,
Hazardous Substances ,
PFAS ,
Public Health ,
Regulatory Requirements ,
State and Local Government ,
Toxic Chemicals ,
Water Quality
Companies subject to the Toxic Substances Control Act (“TSCA”) Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (“PFAS”)—also known as the “TSCA PFAS Reporting...more
9/6/2024
/ Compliance ,
Environmental Protection Agency (EPA) ,
Filing Deadlines ,
Final Rules ,
Hazardous Substances ,
PFAS ,
Reporting Requirements ,
Third-Party ,
Time Extensions ,
Toxic Chemicals ,
Toxic Substances Control Act (TSCA)
In the absence of federal cleanup standards for per- and polyfluoroalkyl substances (“PFAS”) in groundwater, several states have started the process of regulating PFAS in groundwater themselves. As a result, states have...more
On April 19, 2024, the United States Environmental Protection Agency (“EPA”) announced that it is designating perfluorooctanoic acid (“PFOA”) and perfluorooctanesulfonic acid (“PFOS”) as Hazardous Substances under the...more
4/29/2024
/ CERCLA ,
Contamination ,
Department of Transportation (DOT) ,
Discharge of Pollutants ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Final Rules ,
Hazardous Substances ,
Manufacturers ,
PFAS ,
Potentially Responsible Party (PRP) ,
Reporting Requirements ,
Site Remediation ,
Toxic Chemicals ,
Wastewater
On April 10, 2024, the United States Environmental Protection Agency (“EPA”) issued its long-anticipated National Primary Drinking Water Regulation (“NPDWR”) establishing Maximum Contaminant Levels (“MCLs”) for certain PFAS...more
As discussed in more detail in BCLP’s 2023 federal recap client alert, per- and polyfluoroalkyl substances (“PFAS”) were a major focus for the United States Environmental Protection Agency (“EPA”) in 2023, and 2024 will...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
As expected, 2023 was an expansive year for the regulation of per- and polyfluoroalkyl substances (“PFAS”) at the federal level. The United States Environmental Protection Agency (“EPA”) took (or at least proposed)...more
2/8/2024
/ CERCLA ,
Clean Water Act ,
Contaminated Properties ,
Contamination ,
Drinking Water ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Hazardous Substances ,
PFAS ,
Public Health ,
Regulatory Standards ,
Reporting Requirements ,
Toxic Chemicals ,
Toxic Substances Control Act (TSCA) ,
Water Supplies
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
In the absence of an enforceable federal drinking water standard for per- and polyfluoroalkyl substances (“PFAS”) – for the time being anyway - many states have regulated PFAS compounds in drinking water. The result is a...more
1/17/2024
/ Contamination ,
Data Collection ,
Drinking Water ,
Environmental Protection Agency (EPA) ,
Final Rules ,
Hazardous Substances ,
PFAS ,
Proposed Rules ,
Public Comment ,
Regulatory Standards ,
State Regulators ,
Toxic Chemicals ,
Water Supplies
Numerous states have either enacted or proposed regulations regarding per- or polyfluoroalkyl substances (“PFAS”) present in Class B Aqueous Film-Forming Foams (“AFFF”) used for firefighting, or present in firefighters’...more
Marketing campaigns describing products as “green,” “natural,” and “clean” have become increasingly popular as companies seek to attract environmentally conscientious consumers. With a simultaneous increase in public...more
In the absence of enforceable federal standards for per- and polyfluoroalkyl substances (“PFAS”) in soil, several states have started the process of regulating PFAS in soil themselves. These regulations have implications for...more