News & Analysis as of

Comment Period Manufacturers PFAS

Bergeson & Campbell, P.C.

Comments on Maine’s Proposed CUU Amendment Due September 2, 2025

The Maine Department of Environmental Protection (MDEP) began a public consultation on July 30, 2025, on a proposed amendment to Chapter 90: Products Containing Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). The...more

Fox Rothschild LLP

Minnesota Will Continue to Receive Public Comments on Proposed New Rules on PFAS in Products Reporting

Fox Rothschild LLP on

Minnesota’s Pollution Control Agency (MPCA) held a public hearing on May 22, 2025 concerning its proposed rules that would implement PFAS-in-products reporting requirements and associated fees on entities covered by Amara’s...more

Bergeson & Campbell, P.C.

Minnesota Extends Public Comment Period on Proposed PFAS Reporting Rule as Entities Voice Concerns about Compliance with Deadlines...

On May 22, 2025, the Minnesota Pollution Control Agency (MPCA) held a public hearing on its “Proposed Permanent Rules Relating to PFAS in Products; Reporting and Fees” (proposed rule). Administrative Law Judge (ALJ) Jim...more

Bergeson & Campbell, P.C.

EPA Postpones TSCA PFAS Reporting Period to April 2026

The U.S. Environmental Protection Agency announced on May 12, 2025, an interim final rule that would extend the dates of the reporting period for data submitted on the manufacture of perfluoroalkyl or polyfluoroalkyl...more

Faegre Drinker Biddle & Reath LLP

Comment Period Open for Massive New PFAS Reporting Requirements in Minnesota

On April 21, 2025, the Minnesota Pollution Control Agency (MPCA) issued the proposed PFAS in Products: Reporting and Fees Rule for public consultation. The proposed rule details how the MPCA will require manufacturers to...more

Bergeson & Campbell, P.C.

Comments on Minnesota’s Proposed Rule for Reporting Products Containing Intentionally Added PFAS Are Due May 21, 2025

With the January 1, 2026, reporting deadline fast approaching for reporting on products containing intentionally added per- and polyfluoroalkyl substances (PFAS), on April 21, 2025, the Minnesota Pollution Control Agency...more

DLA Piper

Maine DEP Proposes Currently Unavoidable Use Procedures for PFAS in Products Law

DLA Piper on

Maine’s Department of Environmental Protection (DEP) recently published a proposed rule prescribing procedures and criteria for determining Currently Unavoidable Uses (CUU) of intentionally added per- and polyfluoroalkyl...more

Bergeson & Campbell, P.C.

EPA Extends Deadline for Public Comment on Manufacture of Certain PFAS during Fluorination of HDPE and Other Plastic Containers

On November 20, 2024, the U.S. Environmental Protection Agency (EPA) announced an extension to the comment period for the notice published September 30, 2024, seeking public comment on the manufacture of certain per- and...more

Bergeson & Campbell, P.C.

MPCA Requests Comments on Planned PFAS in Products Reporting and Fee Rule

On November 18, 2024, the Minnesota Pollution Control Agency (MPCA) requested comments on planned rules governing reporting and fees paid by manufacturers upon submission of required information about products containing per-...more

Holland & Knight LLP

FDA, PFAS and Food Packaging: More to Come?

Holland & Knight LLP on

The U.S. Environmental Protection Agency (EPA) is not the only federal agency that regulates per- and polyfluoroalkyl substances (PFAS). And states aren't the only ones scrutinizing PFAS in food packaging products. PFAS,...more

Bergeson & Campbell, P.C.

EPA Seeks Comment on Initial Regulatory Flexibility Analysis on Proposed PFAS Reporting Rule

On November 25, 2022, the U.S. Environmental Protection Agency (EPA) announced the availability of and solicited comment on an Initial Regulatory Flexibility Analysis (IRFA) and Updated Economic Analysis following the...more

Beveridge & Diamond PC

EPA Hints at Critical Changes to TSCA PFAS Reporting Rule, Seeks Comment

Beveridge & Diamond PC on

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

Beveridge & Diamond PC

Maine Adopts Broad Ban of PFAS-Containing Products (Updated)

Maine DEP Requests Comments on Concept Draft of Proposed PFAS Regulations - The Maine DEP has issued a “Concept Draft” of proposed regulations that details some of the notification requirements and sales prohibitions for...more

BCLP

Federal PFAS Development: Preliminary Effluent Guidelines Program Plan 15

BCLP on

The United States Environmental Protection Agency (“EPA”) has outlined additional steps that it plans to take to investigate and in some cases regulate the discharge of per- or polyfluoroalkyl compounds (“PFAS”) in certain...more

BCLP

PFAS Update: EPA Proposes Reporting on the Last 10 Years of Manufacture or Import of Products Containing PFAS

BCLP on

The Environmental Protection Agency (“EPA”) is proposing new reporting requirements for Per- and Polyfluoroalkyl Substances (“PFAS”) that would require manufacturers, including importers, to report on their manufacture or...more

Kilpatrick

TSCA’s Information Grab – Manufacturers and Importers Subject to Proposed Expansive Ten-Year “Look Back” PFAS Reporting...

Kilpatrick on

Did you manufacture or import a water repellant t-shirt or a nonstick cooking pan or high performance mountain wear in the past ten years? If so, you could be required to provide ten years of past data and details regarding...more

Woods Rogers

EPA Proposes Retroactive PFAS Reporting

Woods Rogers on

On June 28, 2021, the U.S. Environmental Protection Agency (“EPA”) published a proposed rule that would require a one-time report from companies that manufactured or imported per- and polyfluoroalkyl substances (PFAS) in any...more

BCLP

EPA Proposes New PFAS Requirements Under TSCA

BCLP on

The Environmental Protection Agency (“EPA”) has announced it is taking three actions with respect to per- and polyfluoroalkyl substances (“PFAS”) under the Toxic Substances Control Act (“TSCA”): (1) proposing a rule that is...more

Downey Brand LLP

Proposition 65: Legal and Technical Implications of Listing PFOA as a Carcinogen

Downey Brand LLP on

On March 19, 2021, California’s Office of Environmental Health Hazard Assessment (OEHHA) released a Notice of Intent (NOI) to list perfluorooctanoic acid (PFOA) as a carcinogen under Proposition 65 via the Authoritative...more

Seyfarth Shaw LLP

NDAttention – National Defense Authorization Act (NDAA) Adds Per- and Polyfluoroalkyl Chemicals to TRI

Seyfarth Shaw LLP on

Seyfarth Synopsis: On December 20, 2019, the National Defense Authorization Act for Fiscal Year 2020 (NDAA) was signed into law, including provisions for adding certain per- and polyfluoroalkyl substances (PFAS) to the EPA’s...more

Robinson+Cole Manufacturing Law Blog

PFAS Update: EPA Progress Under PFAS Action Plan

Earlier this year, we wrote about EPA’s PFAS Action Plan, the agency’s blueprint for addressing contamination and protecting public health from per- and polyfluoroalkyl substances (PFAS). ...more

Sullivan & Worcester

PFAS Regulatory Update

Sullivan & Worcester on

As in previous postings, we discuss recent state regulatory initiatives aimed at addressing groundwater and drinking water contamination by per- and polyfluoroalkyl substances ("PFAS"). PFAS are a group of synthetic chemicals...more

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