This alert was originally published on March 20, 2025, and has been revised based on recent developments.
Last year, the U.S. Environmental Protection Agency (EPA) under the Biden administration finalized amendments to...more
Last year, the U.S. Environmental Protection Agency (EPA) under the Biden administration finalized amendments to the procedural framework rule for conducting risk evaluations under the Toxic Substances Control Act (TSCA) that...more
Key Takeaways -
What Happened? On October 11, 2024, the U.S. Environmental Protection Agency (EPA) published a final rule establishing the Emissions Reduction and Reclamation (ER&R) Program to manage certain...more
The U.S. Environmental Protection Agency (EPA) is modifying the Toxic Substances Control Act (TSCA) regulation imposing reporting and recordkeeping requirements for perfluoroalkyl and polyfluoroalkyl substances (the Rule) to...more
Key Takeaways -
The U.S. Environmental Protection Agency (EPA) published proposed revisions to its regulations for decabromodiphenyl ether (decaBDE) and phenol, isopropylated phosphate (3:1) (PIP (3:1)) on November 24. EPA...more
On October 19, 2023, the U.S. Environmental Protection Agency (EPA) published a final rule restricting the use of certain hydrofluorocarbons (HFCs) in aerosols, foams, refrigeration, air conditioning, and heat pump products...more
Key Takeaways -
• What Happened: EPA proposed a new program that would impose leak detection obligations and requirements to use reclaimed hydrofluorocarbons (HFCs) for certain equipment. The proposed rule also includes...more
The U.S. Environmental Protection Agency (EPA) has finalized a one-time reporting rule regarding the manufacture (including import) of per- and polyfluoroalkyl substances (PFAS). Despite heavy industry opposition, obligated...more
Key Takeaways -
What is happening? The U.S. Environmental Protection Agency (EPA) has finalized a rule requiring asbestos manufacturers, importers, and processors to report certain asbestos exposure-related information....more
A new D.C. Circuit opinion addressed the limits of non-delegation doctrine, upheld the U.S. Environmental Protection Agency’s (EPA) authority to regulate HFC/HFO blends, and struck down the agency’s authority to enact...more
On December 15, 2022, the U.S. Environmental Protection Agency (EPA) published a proposed rule restricting the use of certain hydrofluorocarbons (HFCs) in aerosols, foams, refrigeration, air conditioning, and heat pump...more
The U.S. Environmental Protection Agency's (EPA) June 2021 proposal of a Toxic Substances Control Act (TSCA) reporting rule targeting manufacturers of per- and polyfluoroalkyl substances (PFAS) sparked a major outcry from...more
Companies that import, produce, or reclaim HFCs should carefully review – and consider submitting comments on – a new rule proposed by the U.S. Environmental Protection Agency (EPA), which will determine not only the process...more
On December 31, 2021, New York Governor Kathy Hochul signed a new law that imposes obligations on manufactures of consumer “electronic displays,” upholstered furniture, and mattresses. Beginning January 2024, any new products...more
Following up on the short-term extension that it issued in September, EPA has issued a notice of proposed rulemaking that will further extend the compliance deadline for the processing and distribution in commerce of certain...more
October 26, 2021 Update:
Following up on the short-term extension that it issued in September, EPA has issued a notice of proposed rulemaking that will further extend the compliance deadline for the processing and...more
The U.S. Environmental Protection Agency (EPA) published a final rule on October 5, 2021 establishing an allowance allocation and trading program for hydrofluorocarbons (HFCs). The rule implements certain key requirements...more
On May 3, 2021, EPA announced its first major climate change rule under the Biden Administration, proposing to phase down the manufacture and import of hydrofluorocarbons (HFCs), which are potent greenhouse gases. EPA...more
On September 18, 2018, the U.S. Environmental Protection Agency (“EPA”) released an advance copy of a rule proposing to rescind the agency’s 2016 extension (“2016 Rule”) of certain appliance refrigerant leak repair rules to...more
At EPA’s request, the National Research Council (NRC), the policy arm of the National Academy of Sciences, has authored a report that recommends tools and approaches that EPA might use to operationalize its growing focus on...more
Effective January 1, 2015, products imported or manufactured after that date that contain or were manufactured with a hydrochlorofluorocarbon (HCFC) must be labeled before they may be placed into interstate commerce. These...more