More than four years after finalizing reporting requirements for the manufacture, import, export, processing, and distribution in commerce of elemental mercury and mercury-added products, EPA has eliminated an exemption for...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
EPA has issued a prepublication version of a final rule to extend the submission deadline for the TSCA Health and Safety Data Reporting rule to December 1, 2021 for the 20 High Priority Substances, and to January 25, 2022 for...more
Updated September 17, 2021:
EPA continues to extend a key compliance deadline for PIP (3:1). In a final rule effective September 17, 2021, EPA delayed enforcing compliance with the ban on processing and distributing PIP...more
Key Takeaways -
• What is Happening? On July 15, 2021, Maine adopted a law that will ban the use of perfluoroalkyl and polyfluoroalkyl substances (PFAS) in products. While the law takes a phased approach over the next few...more
Section 8(d) of the Toxic Substances Control Act (TSCA) had been effectively a dead provision of TSCA for over a decade. EPA has just revived it by adopting an immediate final rule mandating the submission of health and...more
Do any of the articles, or article components, that your company imports contain PFAS? If so, your company may become subject to extensive reporting requirements proposed by EPA under the Toxic Substances Control Act (TSCA)....more
A federal court has ordered EPA to make extensive changes to its Chemical Data Reporting rule (CDR) with respect to asbestos reporting. While the ruling in ADAO v. Wheeler is limited to CDR reporting of asbestos, it sets the...more
Inventory Reset reporting under the Toxic Substances Control Act (TSCA) seems like years ago, because it was – Form A’s were due February 7, 2018 for manufacturers and October 5, 2018 for processors. Companies are now likely...more
On September 14, the European Commission (Commission) released the roadmap for its Sustainable Products Initiative (Initiative) – an ambitious new vision for legislative reform that will establish minimum sustainability and...more
Five and a half years after proposing changes to its significant new use rules (SNURs) on per- and polyfluoroalkyl substances (PFAS), EPA has finally released a final rule. On June 22, 2020, EPA issued (in prepublication...more
Chemical manufacturers and importers may now begin preparation of their 2020 TSCA Chemical Data Reporting (CDR) submissions in earnest. In two separate pre-publication Federal Register notices, EPA has finalized its 2020 CDR...more
In one action, EPA has solved the problem faced by thousands of companies as they prepare to comply with the Toxic Substances Control Act (TSCA) fees rule self-notification requirement. On March 25, 2020, EPA release a...more
During Inventory Reset in 2017-2018, did your company assert on Form A confidentiality claims for chemical identities on the confidential Toxic Substances Control Act (TSCA) Inventory? If so, you risk having EPA make those...more
Who is subject to the upcoming obligation to self-identify as a manufacturer of a high-priority substance and pay a portion of a fee of more than a million dollars under EPA’s Toxic Substances Control Act (TSCA) fees rule? ...more
The chemical 1,4-dioxane has become a hot topic for EPA and state regulators. New York recently adopted a law banning more than trace amounts of the chemical in cosmetics, personal care products, and cleaning products....more
A centerpiece of EPA’s PFAS Action Plan, issued in February 2019, is finalizing a 2015 proposed rule under the Toxic Substances Control Act (TSCA) that would amend two significant new use rules (SNURs) on some 500...more
By January 1, 2020, the California Cleaning Product Right to Know Act (California RTK Act) will require manufacturers of certain covered cleaning products to make extensive ingredient disclosures on their company websites. By...more
The Maine Department of Environmental Protection (DEP) has proposed a rule designating perfluorooctane sulfonic acid (PFOS) as a priority chemical under the state’s Toxic Chemicals in Children’s Products Law. DEP’s proposal...more
The European Commission (EC) has adopted a new set of eco-design requirements for ten categories of energy-consuming products, including refrigerators, washing machines, and televisions pursuant to the Ecodesign Directive...more
The California State Legislature’s 2019 legislative session concluded this month without a final vote on the session’s highest-profile recycling legislation: the Circular Economy and Pollution Reduction Act (AB 1080/SB 54)....more
Washington State has taken its first steps towards implementing the nation’s strongest state chemicals law. This month, the Department of Ecology (Ecology) announced certain chemical-product combinations that it is studying...more
EPA announced a new policy that the agency will stop sending out notices of deficiency to companies that submit Confidential Business Information (CBI) under the Toxics Substances Control Act (TSCA) without substantiation. 84...more
For the first time in decades, federal legislators will soon consider legislation that would require manufacturers to manage and finance end-of-life recycling programs for product packaging. The bill would reflect...more