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Chemical Data Reporting Rule: 2019 is the Principal Reporting Year

Every four years, domestic manufacturers and importers of chemicals must report to the Environmental Protection Agency under the Chemical Data Reporting rule (CDR). The next reports are due in 2020, with 2019 as the principal...more

Ten Things PMN Submitters Need to Know

Does your company plan to submit a premanufacture notice (PMN) under section 5 of the Toxic Substances Control Act (TSCA)? Has it done so recently? If so, you need to know the answers to ten key questions: - 1. What are...more

California Enacts Broad Prohibitions on Flame Retardant Use

California Governor Jerry Brown has signed into law Assembly Bill (“A.B.”) 2998, restricting the sale of flame retardant-containing children products and furniture. Effective January 1, 2020, A.B. 2998 prohibits any person...more

EPA’s Formaldehyde Standards: Compliance Date Moved Up to June 1, 2018

June 1, 2018 will be the initial compliance date for most companies in the composite wood product industry that are subject to EPA’s Formaldehyde Emission Standards for Composite Wood Products (the Standards). On April 4,...more

TSCA Reform Implementation and Expected 2018 Developments

Some 20 months have passed since the Frank R. Lautenberg Chemical Safety for the 21st Century Act (LCSA) was signed into law, making wide and significant changes to the Toxic Substances Control Act (TSCA). During that time,...more

States Continue to Enact Chemical Legislation in 2017

State legislatures have been relatively active on chemical and material regulations in 2017. As previously reported here, at least 51 bills to regulate chemicals were introduced across the country’s state houses in 2017. ...more

EPA Publishes Background Documents for Five PBT Chemicals, Hosting Webinar in Early September

Persistent, bioaccumulative, and toxic chemicals (PBTs) receive expedited attention under the amended Toxic Substances Control Act (TSCA). The Environmental Protection Agency (EPA) recently released background documents for...more

The TSCA Inventory Reset Begins

Virtually all manufacturers and importers of chemicals for the past 11 years are now subject to a new TSCA reporting requirement known informally as the TSCA Inventory Reset. Reports are due by February 7, 2018. All...more

EPA Releases TSCA Final Rule on Prioritization of High-Priority and Low-Priority Chemical Substances

Under the amended TSCA, prioritization – EPA’s process for selecting which chemical substances to evaluate for possible regulation – is the gatekeeper. EPA has just adopted a final rule describing its process for selecting...more

The TSCA Inventory Reset Clock to Start Ticking

Virtually all manufacturers and importers of chemicals for the past 11 years are now subject to a new TSCA reporting requirement known informally as the TSCA Inventory Reset. Reports will be due six months after the final...more

EPA’s Risk Evaluation Framework Rule Incorporates Key Industry Suggestions

Under the 2016 TSCA amendments, risk evaluation is the critical step toward EPA banning or restricting chemicals, or else determining that they will not be regulated. As required by those amendments, EPA has promulgated a...more

EPA Delays Effective Date of RMP Rule Amendments, Environmental Groups File Challenge

On June 14, 2017, EPA published a final rule in the Federal Register delaying the effective date of its Risk Management Program (RMP) rule amendment package for twenty months, until February 19, 2019. EPA’s decision was...more

TSCA Reform Implementation Update

Eight months have now passed since President Obama signed into law the Frank R. Lautenberg Chemical Safety for the 21st Century Act (LCSA), Pub. Law 114-182, on June 22, 2016. This historic legislation overhauled the Toxic...more

States Consider 51 Bills to Restrict Chemicals in 2017

So far in the 2017 legislative cycle, 16 state legislatures are considering 51 bills seeking to restrict or otherwise regulate chemicals, just 8 months after sweeping changes to the federal Toxic Substances Control Act (TSCA)...more

EPA’s Formaldehyde Standards for Composite Wood Products Pose Challenges for Industry, Particularly Importers

Importers, retailers, and others that sell goods containing plywood or other composite wood products face significant compliance challenges from EPA’s new Formaldehyde Emission Standards for Composite Wood Products (the...more

A Few States Adopt Chemical Legislation Despite TSCA Reform

State legislatures continue to consider legislation to restrict chemicals even as, at the federal level, the Toxic Substances Control Act has been thoroughly overhauled by the Frank R. Lautenberg Chemical Safety for the 21st...more

New TSCA Requirements for Chemical Importers

Companies planning to ship chemical-based products to the United States should have a basic understanding of the Toxic Substances Control Act (TSCA), the key U.S. chemicals law. That law was substantially amended in June...more

EPA’s Formaldehyde Standards for Composite Wood Products Pose Challenges for Industry, Particularly Importers

Importers, retailers, and others that sell goods containing plywood or other composite wood products face significant compliance challenges from EPA’s new Formaldehyde Standards for Composite Wood Products (the Standards)....more

Chemical Data Reporting Rule: The Time Is Now

Every four years, domestic manufacturers and importers of chemicals must report to the Environmental Protection Agency under the Chemical Data Reporting rule (CDR). The next reports are due in three months, on September 30,...more

TSCA Reform Becomes Law; Now the Clock Starts to Tick on Implementation

On June 22, 2016, President Obama signed into law the Frank R. Lautenberg Chemical Safety for the 21st Century Act, H.R. 2576. This historic legislation overhauls the Toxic Substances Control Act (TSCA) for the first...more

What’s New About the Revised TSCA

After years of effort, comprehensive legislation to reform the Toxic Substances Control Act (TSCA) passed the House of Representatives on May 24, 2016. The Frank R. Lautenberg Chemical Safety for the 21st Century Act is...more

The District of Columbia and Washington State Pass Back-to-Back Bans on Flame Retardants

The District of Columbia and the state of Washington recently enacted laws banning the use of listed flame retardants in certain products, ranging from children’s products and residential upholstered furniture in Washington...more

Prop 65 Regulatory Activity Raises New Compliance Questions for Industry

Summary: This post explores recent developments in California under Prop 65, including programmatic changes, new chemical listings, and related litigation. Companies that operate in California should be aware of these...more

States Consider Over 60 Bills Regulating Chemicals in 2016

Although legislation to overhaul the Toxic Substances Control Act (TSCA) is under near-final consideration, states continue to consider restrictions on chemicals. In the absence of TSCA reform, over 20 states are considering...more

Evolving State Green Chemistry Initiatives

States continue to enact new laws and implement a diverse array of programs and requirements seeking to regulate the manufacture, sale, and use of chemicals in products. Some state requirements have a narrow scope limited to...more

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