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Hot Topics in International Trade A Year in Review (Quickly)
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
On August 6, 2025, the U.S. Food and Drug Administration (FDA) became the latest governmental agency to confirm that fluoropolymers are both safe and necessary. After an independent safety review of fluoropolymers in medical...more
The California Senate recently passed a bill, SB 682, that would essentially eliminate the use of per-and polyfluoroalkyl substances (PFAS), also known as “forever chemicals,” in food packaging within the state, as of January...more
First effective in 2024, the Act bans the sale or distribution of various products that contain intentionally added PFAS chemicals. On January 1, 2026, as part of the product phase-out timeline, the new law bans the sale or...more
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
Takeaway: We have written about false advertising cases alleging that consumer products are contaminated with some sort of harmful substance. See, e.g., Federal court dismisses false advertising claims, ruling that studies...more
Last month, the Minnesota Pollution Control Agency (MPCA) announced that it would delay the January 1, 2026, reporting deadline for manufacturers of intentionally added PFAS-containing products. Though MPCA did not provide...more
On July 23, 2025, the Minnesota Pollution Control Agency (MPCA) announced that it will allow manufacturers an additional six months to report required PFAS information, extending the original January 1, 2026, deadline to July...more
PFAS-related litigation continues to climb and to diversify as to claims and parties. See the attached graphics, updated through the second quarter of 2025. We will continue to update these graphics on a quarterly basis....more
The U.S. Department of Defense (DOD) has published a July 2025 report entitled Update on Critical Per- and Polyfluoroalkyl Substance Uses. House Report 118-121, which accompanied the 2024 DOD appropriations bill (H.R. 4365),...more
Under Minnesota’s PFAS in products law, manufacturers of products containing intentionally added per- and polyfluoroalkyl substances (PFAS) must report those products to the Minnesota Pollution Control Agency (MPCA) by...more
The Minnesota Pollution Control Agency (MPCA) announced on July 23, 2025, that it will extend the January 1, 2026, deadline for reporting products containing intentionally added per- and polyfluoroalkyl substances (PFAS) to...more
The United States District Court for the Northern District of California dismissed with prejudice a putative class action against The Procter & Gamble Company (P&G) on July 7, 2025, concerning the labeling of its “Tampax Pure...more
Welcome to the latest edition of our quarterly global supply chain horizons providing you with a update on the key developments from around the world. Cross-Border - China and the US trade deal - On June 27, the PRC...more
After evaluating public comments on its proposed PFAS-in-products reporting rules, the Minnesota Pollution Control Agency (MPCA) has agreed to exercise its authority under section 116.943 of the Minnesota Statutes (Amara’s...more
As reported in our April 11, 2025, blog item, applications for currently unavoidable use determinations for products containing intentionally added perfluoroalkyl and polyfluoroalkyl substances (PFAS) and scheduled to be...more
In July 2025, just days before trial, plaintiffs in Baker et al. v. E.I. Dupont de Nemours and Co. reached a $27 million settlement with Dupont, resolving claims related to the contamination of drinking water in Hoosick...more
In a contentious 5–2 decision, the Wisconsin Supreme Court has dealt an unprecedented blow to the state’s business and manufacturing sector by ruling that the Department of Natural Resources (DNR) can force cleanup of PFAS...more
EPA’s May 13 interim final rule, which extended the start and end dates of the PFAS Toxic Substances Control Act Section 8(a)(7) reporting period for all manufacturers by nine months, was EPA’s second such extension to the...more
On June 20, 2025, the Organisation for Economic Co-operation and Development (OECD) published a report entitled Per- and Polyfluoroalkyl Substances (PFAS) and Alternatives in Hydraulic Oils and Lubricants: Report on...more
FDA Stalls, But States Push to Keep It Clean Congress and FDA lauded the Modernization of Cosmetics Regulation Act (MoCRA), enacted in 2022, as sweeping federal legislation to increase cosmetic safety and quality standards....more
California microplastics case dismissed, MAHA Commission releases its report, federal PFAS priorities change, IARC classifies automotive gasoline, and more....more
Earlier this week, the Minnesota Pollution Control Agency (MPCA) announced it will extend the upcoming reporting deadline under the state’s PFAS-in-Products law. As currently written, the law requires manufacturers of...more
This week the Minnesota Pollution Control Agency (MPCA) posted Parts One and Two of its response to pre-hearing and hearing comments. Part One states that 67 commenters submitted written comments on the April 2025 proposed...more
When the Make America Healthy Again (MAHA) Commission unveiled its Make Our Children Healthy Again Assessment on May 22 (reissued May 28), it framed the document as a clarion call: U.S. regulators must combat childhood...more