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States are rapidly enacting and implementing bans and reporting requirements for per- and polyfluoroalkyl substances (PFAS) in cosmetics, creating a complex and evolving compliance environment for manufacturers, distributors,...more
When Congress passed the fiscal year 2020 National Defense Authorization Act (“NDAA”), it included a mandate that the U.S. Environmental Protection Agency (“EPA”) take steps to require all manufacturers, including importers,...more
With Assembly Bill A3556C, New York joins a growing list of states considering or enacting broad bans on the sale and distribution of products containing per- and polyfluoroalkyl substances ("PFAS")....more
In 2023, the United States Environmental Protection Agency (“EPA”) issued a final rule under the Toxic Substances Control Act (“TSCA”) which requires manufacturers, including importers, of certain per- and polyfluoroalkyl...more
The United States Environmental Protection Agency (“EPA”) started the new year by finalizing two rules involving per- or polyfluoroalkyl substances (“PFAS”) under the Toxic Substances Control Act (“TSCA”) and the Toxic...more
The Situation: In 2019, Congress amended the Toxic Substances Control Act ("TSCA") to require the Environmental Protection Agency ("EPA") to promulgate a reporting rule on per- and polyfluoroalkyl substances ("PFAS"). EPA...more
On October 11, 2023, the U.S. Environmental Protection Agency (EPA) published a final rule under the Toxic Substances Control Act (TSCA) Section 8(a)(7), requiring manufacturers to submit a one-time report to the Agency...more
The U.S. Environmental Protection Agency (EPA) published a far-reaching and enormously important final rule (Rule) on Oct. 11, 2023, requiring comprehensive reporting of per- and polyfluoroalkyl substances (PFAS) manufactured...more
On February 14, 2023, the Maine Department of Environmental Protection (MDEP) issued a proposed draft rule that provides guidance on reporting requirements and sales prohibitions for products and product components containing...more
Multiple states have enacted laws that impose prohibitions or notification obligations on the commercial distribution of PFAS-containing products, with requirements under the laws of three states (California, Maine and New...more
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
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
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