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Toxic Chemicals Importers

Holland & Knight LLP

PFAS in Cosmetics: State-Led Regulatory Surge Demands Proactive Compliance

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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

Bergeson & Campbell, P.C.

EPA Publishes Preliminary Lists of Manufacturers (Including Importers) Subject to Fees for Risk Evaluations

On December 31, 2024, the U.S. Environmental Protection Agency (EPA) announced the availability of and solicited comment on the preliminary lists of manufacturers (including importers) subject to fees for the next five...more

Wiley Rein LLP

TSCA 2024 CDR Reporting Deadline Extended -- Confirm Your CBI is Protected

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On September 27, 2024, the U.S. Environmental Protection Agency (EPA) published a final rule extending the submission deadline for the 2024 Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) from September 30...more

Downey Brand LLP

EPA’s Final Rule Enhances Risk Evaluations Process For Scrutiny of TSCA Chemicals

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On May 3, 2024, the Environmental Protection Agency (EPA) published its Final Rule that amends the risk evaluation process for chemicals under the Toxic Substances Control Act (TSCA) and the steps chemical manufacturers and...more

Holland & Knight LLP

Product Importers: Are You Ready for the New PFAS Reporting Requirements Under TSCA?

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The U.S. Environmental Protection Agency (EPA) published a far-reaching and important final rule (Rule) on Oct. 11, 2023, requiring comprehensive reporting of per- and polyfluoroalkyl substances (PFAS) manufactured and...more

Williams Mullen

Communication is Key: OSHA’s Amended Hazard Communication Standard

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OSHA is amending its Hazard Communication Standard (HCS) regulations which require chemical manufacturers and importers to classify the hazards of chemicals they produce or import and to provide their employees information...more

Conn Maciel Carey LLP

[Webinar] Major Updates to OSHA's Hazard Communication (Chemical Right-to-Know) Standard - June 20th, 1:00 pm ET

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On May 20, 2024, OSHA published its long-in-the-making revision to the Hazard Communication Standard (HCS). OSHA’s revised its standard to better align with the United Nations’ Globally Harmonized System of Classification...more

Wiley Rein LLP

[Webinar] EPA Risk Evaluations Under TSCA: What’s at Stake and How to Prepare - May 16th, 12:00 pm - 1:00 pm EDT

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On May 3, 2024, the U.S. Environmental Protection Agency’s (EPA) final rule on procedures for chemical risk evaluation under the Toxic Substances Control Act (TSCA) was published in the Federal Register. In the words of EPA’s...more

Holland & Knight LLP

FDA Ramps Up Actions on PFAS

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With the completion of the voluntary phaseout of one form of short-chain per- and polyfluoroalkyl substances (PFAS) as a grease-proofing agent, the U.S. Food and Drug Administration (FDA) has rejected the view that...more

BCLP

EPA’s Noncomprehensive List of PFAS Subject to the TSCA Reporting Rule

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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

BCLP

PFAS Update: EPA Kicks Off the New Year with TSCA and TRI Actions

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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

Jones Day

EPA's PFAS Reporting Rule Requires Broad Retroactive Disclosure of PFAS Data

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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

Holland & Knight LLP

EPA Publishes Comprehensive PFAS Reporting Rule Under TSCA

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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

Jenner & Block

Maine Proposed Rule Provides Further Reporting Clarity for Products and Product Components Containing PFAS

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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

Pillsbury Winthrop Shaw Pittman LLP

Effective January 1, 2023, Numerous States Begin to Impose Notification Requirements and Prohibitions on Products Containing...

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

BakerHostetler

IRS Provides Initial and Limited Guidance on Newly Reinstated ‘Superfund Tax’

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Last month, the IRS published Notice 2021-66, issued in response to the Infrastructure Investment and Jobs Act’s (Jobs Act) reinstatement of the previously expired “Superfund Tax”—an excise tax imposed on manufacturers,...more

Woods Rogers

EPA Proposes Retroactive PFAS Reporting

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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

Beveridge & Diamond PC

Article Importers May Face Another TSCA Obligation, This One Related to PFAS

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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

Littler

OSHA Proposes Changes to Align Hazard Communication Standard with GHS Revision 7

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On February 16, 2021, the Department of Labor’s Occupational Safety and Health Administration (OSHA) published in the Federal Register a notice of proposed rulemaking to update its Hazard Communication Standard (HCS)....more

Wiley Rein LLP

U.S. Brands Importing Finished Goods to the European Union – Are You Ready for the January 5, 2021, Submission Deadline for SCIP?

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SCIP, of course, stands for “Substances of Concern In Articles, as such or in Complex Objects (Products)”. And, despite widespread speculation that the deadline for reporting would be extended, the anticipated deadline of...more

BCLP

European Chemicals Agency SCIP Database is launched and ready for use

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At the end of October, the European Chemicals Agency (ECHA) launched the SCIP database. When populated, the database will ensure that information on articles in the EU that contain substances of very high concern (SVHCs) is...more

Wiley Rein LLP

TSCA Cost Sharing Consortias Are Broken Due to EPA Rule – Can They Be Fixed?

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Under the EPA fee rule for TSCA (40 C.F.R. § 700.45), manufacturers (including importers) of chemicals undergoing risk evaluation are subject to the TSCA fee of $1.35 million. Following publication of a preliminary list of...more

Society of Corporate Compliance and Ethics...

SCIP: Maintaining direct and indirect revenue streams

Report on Supply Chain Compliance 3, no. 19 (October 1, 2020) - As the deadline for companies to submit data to the European Union’s Substances of Concern In articles, as such or in complex objects (Products) (SCIP)...more

BCLP

EPA Modifies Classes of Manufacturers and Importers Subject to TSCA Fees Rule for High-Priority Substances in the U.S.

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One of the hallmarks of the 2016 United States TSCA reform bill was the creation of a risk evaluation process for certain chemical substances. To implement this risk evaluation process, EPA promulgated regulations regarding...more

Vedder Price

The Long Reach of Proposition 65

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According to the Center for Accountability in Science, since 2010, businesses have spent over $182 million to settle Prop 65 lawsuits. What most companies do not realize is that 75% of settling businesses were headquartered...more

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