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D.C. Circuit Restarts Litigation over EPA’s PFAS Drinking Water Standards, Continues Pause in CERCLA Litigation

On July 22, 2025, the U.S. Court of Appeals for the District of Columbia (D.C.) Circuit granted a motion by the Environmental Protection Agency (EPA) to lift the abeyance in consolidated litigation challenging the agency’s...more

D.C. Circuit Grants Latest Abeyance Extension in PFAS MCL Litigation

On June 5, 2025, the U.S. Court of Appeals for the D.C. Circuit granted the EPA’s third request to continue holding in abeyance consolidated litigation challenging the agency’s national drinking water regulation for six per-...more

EPA Issues Second Extension of PFAS Reporting Timeline Under TSCA Section 8(a)(7)

On May 12, 2025, EPA announced that it will again revise the reporting timeline for manufacturers of per- and polyfluoroalkyl substances (PFAS) under Section 8(a)(7) of the Toxic Substances Control Act (TSCA). The data...more

EPA’s PFAS Strategy Evolves Amid Continued Regulatory, Legislative, and Litigation Uncertainty

While the Trump administration’s PFAS policy framework is beginning to take shape, uncertainties remain across the regulatory, litigation and legislative fronts. On April 28, EPA Administrator Lee Zeldin announced a set of...more

PFAS, HFCs and Related Chemicals in the Data Center Industry

Data centers use various chemicals that have recently been the focus of regulatory efforts at the federal and state level. The historic or future use of these chemicals may create liabilities, obligations, or new costs for...more

Presidential Memo Directs Immediate Repeal of Regulations Without Public Notice and Comment

Continuing with the Trump administration’s deregulatory agenda, the White House issued a Presidential Memorandum on April 9 titled Directing the Appeal of Unlawful Regulations. It instructs executive agencies to repeal...more

Congressional Allocation Signifies EPA Intent to Maintain the One-Time PFAS Reporting Rule Under TSCA Section 8(a)(7)

Recently, Congress allocated approximately $17 million in EPA’s fiscal year 2025 budget to modernize outdated technical systems and accelerate chemical reviews which may help resolve ongoing concerns about the functionality...more

EPA Signals Potential PFAS Policy Pivot Under New Administrator

In March, EPA Administrator Lee Zeldin addressed top state environmental officials, highlighting the Agency’s priorities for the year ahead. Without committing the EPA to an official stance, Zeldin reaffirmed his commitment...more

Maryland Files PFAS Suit Against Downstream Manufacturer

Maryland has filed suit against W.L. Gore & Associates (Gore), a downstream user of PFAS-containing materials, alleging that its manufacturing processes contributed to PFAS contamination through its use of...more

Court Approves 60-Day Stays in Legal Battles over Biden-Era PFAS Regulations amid Administration Shift

In a move that signals potential policy shifts under the new administration, the U.S. Court of Appeals for the District of Columbia Circuit granted EPA’s requests for 60-day stays in two high-profile cases challenging...more

Uncertain Times Ahead for EPA Regulation of PFAS

With 2024 winding down and a change of presidential administration imminent, it is worthwhile to consider the state of EPA’s efforts to regulate per- and polyfluoroalkyl substances (PFAS). In this connection, EPA recently...more

New Lawsuit Highlights PFAS Exposure for Fertilizer Manufacturers

A lawsuit filed earlier this year highlights potential PFAS liability exposure for fertilizer manufacturers, especially those that produce biosolid-based products. Five Texas farmers have sued Synagro Technologies, alleging...more

Bipartisan Legislation Presents Opportunity for Passing PFAS Laws

On September 19, the Senate Armed Services Chairman released the final Manager’s Amendment for the National Defense Authorization Act (NDAA)—signaling that it is now time for the House and Senate to negotiate this “must-pass”...more

EPA Issues Proposed Rule Adding New PFAS to the Toxics Release Inventory (TRI)

On October 1, 2024, the U.S. Environmental Protection Agency (EPA) proposed to add 16 individual per- and polyfluoroalkyl substances (PFAS) as well as 15 PFAS categories, representing over 100 PFAS to the Toxics Release...more

EPA Gathering Information for Another Possible TSCA Section 6 Rulemaking

On September 30, 2024, the U.S. Environmental Protection Agency (EPA) issued a notice seeking comment on the manufacture of certain per- and polyfluoroalkyl substances (PFAS) during the fluorination of high-density...more

EPA Issues Eight-Month Delay of the Reporting Period for the PFAS Reporting Rule under TSCA Section 8(a)(7)

On September 5, the U.S. Environmental Protection Agency (EPA) cut industry a significant break by postponing the reporting period for the one-time reporting rule for per- and polyfluoroalkyl substances (PFAS) under Section...more

The End of Chevron Deference Could Spell Trouble for EPA’s PFAS “Hazardous Substance” Rule

A recent Supreme Court ruling could further jeopardize EPA’s PFAS hazardous substance designation, as the agency is attempting to advance a novel use of delegated legislative authority to further regulate PFAS chemicals....more

EPA Finalizes Rule Designating PFAS Substances as Hazardous Constituents Under CERCLA

On April 19, 2024, the Environmental Protection Agency (EPA) finalized its long-awaited rule designating two PFAS compounds, perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), as “hazardous substances”...more

PFAS Hazardous Substance Designation Clears White House Review, Nearing Finalization

The Biden Administration is continuing its efforts to regulate per- and polyfluoroalkyl substances (PFAS). On April 15, 2024, the White House Office of Management and Budget (OMB) completed its review of an Environmental...more

EPA Finalizes Stringent Regulation of PFAS in Drinking Water

On April 10, 2024, the Environmental Protection Agency (EPA) finalized a National Primary Drinking Water Regulation under the Safe Drinking Water Act to establish Maximum Contaminant Levels (MCLs) for five per- and...more

Finalized EPA Drinking Water and CERCLA Regulations Fast Approaching  

The Environmental Protection Agency (EPA) is continuing its push to regulate per- and polyfluoroalkyl substances (PFAS). Just last week, the agency’s revised PFAS regulations under the Safe Drinking Water Act (SDWA) cleared a...more

EPA Proposes to Designate Nine PFAS Compounds as Hazardous Constituents, Seeks Industry Input

The clock is winding down on businesses interested in commenting on EPA’s proposal to designate nine per- and polyfluoroalkyl substances (PFAS) as hazardous constituents under the Resource Conservation and Recover Act (RCRA)....more

Major PFAS Legislation Stalled Amid Debate on PFAS Liability for Passive Receivers

As in 2023, Congress continues to focus on PFAS issues in the first months of 2024. In this 118th Congress, at least 39 bills focused on PFAS have been introduced along with several dozen additional bills that tangentially...more

EPA Updates PFAS TRI Reporting Requirements

On October 2023, the U.S. Environmental Protection Agency (EPA) published a final rule in the Federal Register modifying reporting requirements for per- and polyfluoroalkyl substances (PFAS) in the Toxics Release Inventory...more

EPA Drops Pre-Publication of the Long-Anticipated Final Version of Its One-Time PFAS Reporting Rule under TSCA Section 8(a)(7)

On September 28, 2023, the U.S. Environmental Protection Agency (EPA) finalized the long-awaited one-time reporting rule for per- and polyfluoroalkyl substances (PFAS) that the Agency had proposed in June 2021 under Section...more

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