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The Delayed, but Not Forgotten, Disclosure of PFAS: TSCA Section 8(a)(7) Postponed While States Fill the Gaps

When Congress passed the fiscal year 2020 National Defense Authorization Act (“NDAA”), it included a mandate that the U.S. Environmental Protection Agency (“EPA”) take steps to require all manufacturers, including importers,...more

Maine Narrows and Delays PFAS Regulation

Overshadowed by the U.S. Environmental Protection Agency’s (EPA) regulation of PFAS under the Safe Drinking Water Act and its designation of PFOS and PFOA as hazardous substances under CERCLA, Maine’s latest revision to its...more

New EPA PFAS Reporting Rule May Pose Challenge for Manufacturers and Importers

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

PFAS Reporting Obligations in 2023: Key Issues and Considerations

In recent months federal and state regulators have proposed or finalized new regulations that require chemical and product manufacturers to disclose the manufacture and use of PFAS (perfluoroalkyl and polyfluoroalkyl...more

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