Blogs

Bergeson & Campbell, P.C.’s (B&C®) recently published Forecast 2026 includes a deep dive into what stakeholders can expect this year regarding the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), excerpts of which are shared here. Policy shifts and uncertainties are expected under FIFRA and the Endangered Species Act (ESA) in the agricultural and biocidal area. ESA has been, and will continue to be, the most important issue affecting pesticide use and regulation in the...

The House Committee on Energy and Commerce posted a Hearing Memorandum on January 20, 2026, for the January 22, 2026, hearing entitled “Chemicals in Commerce: Legislative Proposal to Modernize America’s Chemical Safety Law, Strengthen Critical Supply Chains, and Grow Domestic Manufacturing.” According to the Hearing Memorandum, the Subcommittee on Environment will hear from the following witnesses: Dimitrios Karakitsos, Holland & Knight; Kimberly Wise White, Ph.D., American Chemistry...

Bergeson & Campbell, P.C.’s (B&C®) recently published Forecast 2026 includes a deep dive into what stakeholders can expect this year regarding the Toxic Substances Control Act (TSCA), covering a comprehensive set of topics, including existing chemical risk evaluations and rulemakings, new chemical reviews, pending legal challenges, personnel and organizational changes, and much more. In the TSCA existing chemicals program, for example, the U.S. Environmental Protection Agency (EPA)...

As the 2026 election cycle comes into sharper focus, Congress is entering a period of unusual transition. A growing number of Republican lawmakers as well as some Democrats have announced retirements, resignations, or decisions not to seek re-election. This reflects internal strain within the party and broader dissatisfaction with the pace and structure of congressional governance. While political realignments are not new, the current trend raises important questions about how sustained turnover...

The House Energy and Commerce Subcommittee on Environment will hold a legislative hearing on January 22, 2026, entitled “Chemicals in Commerce: Legislative Proposal to Modernize America’s Chemical Safety Law, Strengthen Critical Supply Chains, and Grow Domestic Manufacturing.” According to the House Energy and Commerce Committee’s January 15, 2026, press release, since the Committee’s “first hearing of this Congress, our Committee has been working to modernize the Toxic Substances...

The U.S. Environmental Protection Agency (EPA) announced on January 6, 2026, the availability of the final risk evaluations under the Toxic Substances Control Act (TSCA) for butyl benzyl phthalate (BBP), dibutyl phthalate (DBP), dicyclohexyl phthalate (DCHP), diethylhexyl phthalate (DEHP), and diisobutyl phthalate (DIBP). 91 Fed. Reg. 373. EPA states that it “used the best available science to prepare these final risk evaluations, and determined, based on the weight of scientific evidence,...

The March 1, 2026, deadline for all establishments, foreign and domestic, that produce pesticides, devices, or active ingredients to file their annual production for the 2025 reporting year is fast approaching. Pursuant to Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Section 7(c)(1) (7 U.S.C. § 136e(c)(1)), “Any producer operating an establishment registered under [Section 7] shall inform the Administrator within 30 days after it is registered of the types and amounts of...

On January 5, 2026, the U.S. Environmental Protection Agency (EPA) invited nominations for scientific experts for appointment to the Science Advisory Committee on Chemicals (SACC), established pursuant to the Toxic Substances Control Act (TSCA). 91 Fed. Reg. 263. EPA also requested nominations of scientific and technical experts whom EPA can consider for service as ad hoc peer reviewers assisting SACC. 91 Fed. Reg. 275. EPA states in a December 31, 2025, press release that for 2026, it is...

As part of the activities of the European Union (EU) Observatory for Nanomaterials (EUON), the European Chemicals Agency (ECHA) has commissioned a study on “Nanomaterials used as or integrated into flame retardants.” According to EUON, the study aims to collect and review scientific and market information on nanomaterials used as or integrated into flame retardants in consumer and professional products. EUON states that the objective is to assess their performance, potential health and...

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As reported in our September 12, 2025, blog item, under the 2016 Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg Act) amendments to the Toxic Substances Control Act (TSCA), most confidential business information (CBI) claims will expire after ten years unless reasserted and substantiated. This means that a CBI claim made in 2016 will expire in 2026 unless the claim is reasserted and resubstantiated before the end of the ten-year period. The U.S. Environmental Protection...

On January 5, 2026, the U.S. Environmental Protection Agency (EPA) announced the availability of a draft Pesticide Registration (PR) Notice entitled “Pesticide Registration Notice 2026-NEW: Notifications, Non-Notifications, and Minor Formulation Amendments.” 91 Fed. Reg. 271. EPA stated that it is issuing this draft PR Notice to align with changes to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), including through the Pesticide Registration Improvement Act (PRIA), and to...

The U.S. Department of Agriculture (USDA) announced on December 30, 2025, several coordinated actions intended to emphasize American agricultural research and innovation “by ensuring ideas stay in America or among our allies, not with hostile nations and that we are putting American farmers and ranchers first in every USDA program, period.” The actions include advancing the Trump Administration’s efforts to end subsidies for foreign-controlled energy sources and strengthen domestic supply...

On December 2, 2025, the Organisation for Economic Co-operation and Development (OECD) published a policy brief entitled “Financing instruments and policy levers to harness biomanufacturing for climate, biodiversity and growth.” According to OECD, biomanufacturing can enhance supply chain resilience, advance climate action, augment biodiversity conservation efforts, and contribute to economic growth. Although many Group of 20 (G20) countries support bioeconomy innovation, targeted financial...

As required under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), on December 29, 2025, the U.S. Food and Drug Administration (FDA) published a Report on the Use of PFAS in Cosmetic Products and Associated Risks. The scope of the report is limited to per- and polyfluoroalkyl substances (PFAS) intentionally added to cosmetic products as ingredients and does not include PFAS that may be present in the final product as contaminants. According to the report, “[c]ertain PFAS are...

On December 12, 2025, the Organisation for Economic Co-operation and Development (OECD) published a report entitled Safe and sustainable by design tools, integrative systems and platforms for nanomaterials and nano-enabled products. According to OECD, the report advances the implementation of safe and sustainable by design (SSbD) for nanomaterials by compiling and reviewing tools, integrative systems, and platforms that support design, risk assessment, and sustainability considerations. The...

On December 19, 2025, the National Security Commission on Emerging Biotechnology (NSCEB) announced the publication of a paper entitled “The Future of U.S.-China Biotechnology Competition.” The paper notes that although the United States has historically led in biotechnology, over the past 20 years, China has systematically built a vertically integrated biotechnology ecosystem that is now in prime position to challenge U.S. leadership. According to the paper, China’s new competitive posture...

The U.S. Environmental Protection Agency (EPA) announced on December 23, 2025, that under the Trump Administration, EPA “is dramatically expanding its imports investigative capacity and enforcement scope beyond the limited efforts of previous years, launching broader investigations that target illegal pesticide and chemical smuggling operations across multiple sectors to safeguard communities, agricultural integrity, and national security.” According to EPA, this increased enforcement...

On December 4, 2025, the Council of the European Union (EU) reached a provisional agreement with the European Parliament (EP) on rules establishing a legal framework for new genomic techniques (NGT). According to the Council’s press release, the provisional agreement “guarantees a simplified process for NGT plants equivalent to conventional plants and addresses concerns regarding intellectual property and access to seeds.” There would be two ways for NGT plants to be placed on the market:...

On January 15, 2026, the Organisation for Economic Co-operation and Development (OECD) will hold a webinar on its recent report, Synthesis Report on Understanding Fluoropolymers and Their Life Cycle. As reported in our December 15, 2025, blog item, the report provides a synthesis of the global fluoropolymer market, exploring the identities and life cycles of fluoropolymers, the presence of other per- and polyfluoroalkyl substances (PFAS) in commercial products, their degradation through...

On December 12, 2025, the Organisation for Economic Co-operation and Development published a report entitled The Identification of Exposure Metrics for Use in Evaluation of Inhalation Exposure to Nano-Objects and their Aggregates and Agglomerates (NOAA) in the Workplace. The report presents a comprehensive overview, informed by a literature review, on methods for assessing and measuring inhalation exposure to nano-objects and their aggregates and agglomerates (NOAA) in workplace environments....

The U.S. Environmental Protection Agency (EPA) has released the annual pesticide registration maintenance fee materials for fiscal year (FY) 2026. The deadline for payment of EPA’s annual maintenance fee for pesticide registration is January 15, 2026. Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Section 4(i)(1)(A) requires everyone who holds an active or suspended pesticide registration granted under FIFRA Sections 3 and 24(c) (special local needs) to pay an annual maintenance...

As 2025 draws to a close, one of the most consequential, but least publicly discussed, shifts in federal environmental governance has been the quiet expansion of artificial intelligence (AI) behind the scenes across multiple federal agencies. AI tools are not new in federal science programs, but 2025 marked a turning point: agencies began integrating machine-learning models into routine workflows in exposure modeling, surveillance, enforcement targeting, and environmental monitoring. The White...

On December 15, 2025, the European Commission (EC) announced a legislative package that includes a proposal for a regulation to establish measures to strengthen the European Union’s (EU) biotechnology and biomanufacturing sectors (Biotech Act). The questions and answers (Q&A) on the Biotech Act note that the proposal is focused on health biotech, “although it also includes provisions on food and feed.” According to the Q&A, the Biotech Act would amend specific parts of EU health...

The U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) announced on December 16, 2025, that its Biotechnology Regulatory Services (BRS) has rescheduled its annual stakeholder meeting for February 26, 2026. The meeting will be held in-person at the National Agricultural Library, 10301 Baltimore Avenue Beltsville, Maryland, with an option for virtual attendance. According to APHIS, attendees will receive updates about: Highlights from fiscal year 2025; Looking...

The New York State Department of Environmental Conservation (NYS DEC) issued on December 11, 2025, a suite of per- and polyfluoroalkyl substances (PFAS) response actions and resources intended to protect communities. The materials released include a new progress report detailing New York State’s leadership in addressing PFAS; a new study on the presence of PFAS on the landscape; final wastewater treatment plant guidance that protects drinking water and other surface waters; proposed new...

On December 1, 2025, the European Union (EU) Observatory for Nanomaterials (EUON) announced the availability of a report analyzing the applications of nano-enabled textiles and their presence on the EU and global markets. The report, Information on Nano-Enabled Textiles, addresses the growing integration of nanotechnology in the textile industry, which has introduced advanced functionalities such as antimicrobial properties, enhanced durability, water repellence and ultraviolet (UV) protection....

On November 14, 2025, the Organisation for Economic Co-operation and Development (OECD) published a report entitled Synthesis Report on Understanding Fluoropolymers and Their Life Cycle. The report provides a synthesis of the global fluoropolymer market, exploring the identities and life cycles of fluoropolymers, the presence of other per- and polyfluoroalkyl substances (PFAS) in commercial products, their degradation through processing, use, and end-of-life treatment, as well as their...

On December 18, 2025, the House Energy and Commerce Subcommittee on Environment will hold a hearing on “Examining the Impact of EPA’s CERCLA Designation for Two PFAS Chemistries and Potential Policy Responses to Superfund Liability Concerns.” In May 2024, the U.S. Environmental Protection Agency (EPA) issued a final rule designating perfluorooctanoic acid (PFOA), perfluorooctanesulfonic acid (PFOS), and their salts and structural isomers as hazardous substances under the Comprehensive...

It appears increasingly likely that the U.S. Environmental Protection Agency (EPA) and other federal agencies will face yet another shutdown at the end of January 2026. When Congress failed to pass appropriations legislation for the 2026 fiscal year (FY) by September 30, 2025, what ensued was a record-setting 43-day closure of the U.S. government. November 12, 2025’s, Hail Mary Senate agreement funds the government at existing spending levels -- but only until January 30, 2026. The bill that...

The United Nations (UN) Special Rapporteur on toxics and human rights has called for input on a thematic report on “forever chemicals (PFAS) and human rights.” According to the UN, the report will identify how the adverse impacts of per- and polyfluoroalkyl substances (PFAS), including pathways to exposure, relate to potential human rights violations. The report “will also analyze gaps and shortcomings in the national, regional, and multilateral legal frameworks governing forever...

On December 8, 2025, the Minnesota Pollution Control Agency (MPCA) published in the Minnesota State Register a final rule regarding per- and polyfluoroalkyl substances (PFAS) in products reporting and fees. MPCA revised the proposed rule to correct defects identified by an August 2025 administrative law judge’s (ALJ) report. MPCA also made other non-substantial changes. Under the final rule, manufacturers of products containing intentionally added PFAS are required to report certain...

Beginning July 1, 2026, Connecticut will require that certain consumer products containing intentionally added per- and polyfluoroalkyl substances (PFAS) be labeled. The products subject to the labeling requirement include apparel; carpets or rugs; cleaning products; cookware; cosmetic products; dental floss; fabric treatments; juvenile products; menstruation products; textile furnishings; ski wax; or upholstered furniture. Under an order that took effect December 1, 2025, the following phrases...

The European Commission (EC) announced on November 26, 2025, that it adopted a new Strategic Framework for a Competitive and Sustainable EU Bioeconomy, “charting a way forward to build a clean, competitive and resilient European economy.” According to the EC, by using renewable biological resources and providing alternatives to critical raw materials, the European Union (EU) “will move forward towards a more circular and decarbonised economy and can decrease dependence on fossil...

On November 23, 2025, the Organisation for Economic Co-operation and Development (OECD) published a policy brief entitled “Boosting biotechnology innovation through agile regulation and finance instruments.” The policy brief explores the investment and regulatory policy landscapes in the European Union (EU) and the United States, “highlighting shared challenges and lessons that can help accelerate sustainable innovation and strengthen participation in the global bioeconomy.” The policy...

On November 25, 2025, the National Security Commission on Emerging Biotechnology (NSCEB) announced the publication of a discussion paper entitled “The Future of Science: A Playbook for Accelerating American Innovation.” According to NSCEB, the paper is “the first in a series of fresh analyses” that NSCEB will publish following the publication of its final report and action plan for Congress in April 2025. The paper represents observations from NSCEB, drawn from consultations with a range...

On November 13, 2025, the California Department of Pesticide Regulation (DPR) held a webinar to discuss potential changes to its Enforcement Response Regulations set forth at 3 C.C.R. Sections 6128 and 6130. DPR also released its Discussion Document explaining the various regulatory “concepts” it is considering and posing questions for public input related to those concepts.  The proposed focus areas are designed to address areas of improvement identified in a U.S. Environmental...

On November 21, 2025, the U.S. Department of Agriculture (USDA) announced that it is making $7 million in payments available to advanced biofuel producers nationwide through its Advanced Biofuel Payment Program, a provision of the One Big Beautiful Bill. USDA states that the funding is aimed at increasing the production of American-grown biofuels. According to USDA, the Program supports expanding the production of advanced biofuels by paying advanced biofuel producers for finished advanced...

The U.S. soybean industry remains a focal point in the intersection of American agriculture, global trade policy, and federal regulatory action. Ongoing trade tensions -- particularly between the United States and China -- have reshaped the global soybean value chain, while rising input costs, labor constraints, and regulatory uncertainty create additional pressures for farmers. In recent months, attention has turned toward how the reopening of the federal government -- after extended funding...

Headlines regarding the U.S. Environmental Protection Agency’s (EPA) most recent proposed update to the one-time per- and polyfluoroalkyl substances (PFAS) reporting rule under Toxic Substances Control Act (TSCA) Section 8(a)(7) have been dominated by the rule’s new exemptions and the significant narrowing of responsibility and burden that industry stakeholders will face if the rule becomes final. But, buried in the preambular text -- Unit III.A.2 to be precise -- are a few paragraphs that...

The American Chemical Society (ACS) and Bergeson & Campbell, P.C. (B&C®) are pleased to present “31st Annual Green Chemistry Challenge Awards: New Categories and Expanded Opportunities,” on December 4, 2025, from 11:00 a.m. - 12:00 p.m. (EST).  2026 marks the 31st year that the ACS and partners have spurred American innovation by soliciting, evaluating, selecting, and amplifying remarkable chemical products and processes through the highly coveted Green Chemistry Challenge Awards...

On November 18, 2025, Senators Chris Coons (D-DE) and Ted Budd (R-NC) introduced the Biomanufacturing Excellence Act, which would promote U.S. leadership in biotechnology and strengthen domestic biopharmaceutical manufacturing. Coons’ November 18, 2025, press release states that “[b]iotechnology will shape how the United States defends itself, secures its food supply, and cures life-threatening diseases.” According to the National Security Commission on Emerging Biotechnology’s (NSCEB)...

The United Kingdom (UK) NanoSafety Group (UKNSG) has published the third edition of its guidance entitled “Working Safely with Nanomaterials in Research & Development.” The guidance is intended to provide help and support to research laboratories in industry, research, and training organizations and academia on how to comply with their occupational health and safety legal obligations. The guidance also includes additional information to help improve health and safety systems when working...

On November 14, 2025, the U.S. Environmental Protection Agency (EPA) further postponed the effective date of the Toxic Substances Control Act (TSCA) Section 6(g) exemption requirements in the final risk management rule for tricholoroethylene (TCE) until February 17, 2026. 90 Fed. Reg. 51027. According to EPA’s November 13, 2025, press release, “[t]his will ensure that the timing of EPA’s administrative stay aligns with the court’s timeframe for this action.” EPA’s December 17, 2024,...

The U.S. Environmental Protection Agency (EPA) has posted a web page entitled “Pesticides Containing a Single Fluorinated Carbon.” The web page includes a list of frequently asked questions (FAQ) regarding pesticidal substances containing a single fluorinated carbon and how EPA evaluates them. EPA intends the FAQs to inform the public better about EPA’s gold-standard science pesticide registration process. EPA notes that the web page “does not, and is not intended to, interpret or amend...

On November 19, 2025, the U.S. Senate Committee on Environment and Public Works will hold a hearing examining per-and polyfluoroalkyl substance (PFAS) cleanup and disposal policy. The Committee is scheduled to hear from the following witnesses: Eric Gerstenberg, Co-Chief Executive Officer, Clean Harbor; Leah Pilconis, General Counsel, Associated General Contractors of America; and Kate R. Bowers, Supervisory Attorney, Congressional Research Service.

On November 10, 2025, the U.S. Environmental Protection Agency (EPA) announced that it is rescheduling the November 18, 2025, preparatory meeting for the Science Advisory Committee on Chemicals (SACC). The meeting to consider the scope and clarity of the draft charge questions for SACC’s peer review of EPA’s draft risk evaluation for octamethylcyclotetrasiloxane (D4) will now be held virtually on December 1, 2025. Registration for the meeting is open. To present oral comments during the...

The U.S. Environmental Protection Agency (EPA) announced on November 10, 2025, that it will publish a final rule extending the compliance date for laboratories using methylene chloride to ensure long-term compliance with the requirements of the May 2024 final risk management rule. According to EPA, the final rule will extend the Workplace Chemical Protection Program (WCPP) compliance dates for non-federal laboratories by an additional 18 months, aligning them with the dates required for federal...

On Wednesday, November 5, 2025, the Supreme Court of the United States heard arguments on executive tariff authority, a case that promises to have ripple effects far beyond the bounds of pure trade law. Trump v. V.O.S. Selections, Inc., No. 25-250. In the chemical sector -- where global chemical feedstocks, complex supply chains, and regulatory compliance are already famously complicated -- the stakes are especially high. If the Court limits or invalidates the President’s ability unilaterally...

On October 29, 2025, Public Employees for Environmental Responsibility (PEER) announced that it filed an Information Quality Act (IQA) request with the U.S. Environmental Protection Agency (EPA) regarding statements on EPA’s website that perfluorooctanoic acid (PFOA) has been phased out of domestic production. According to PEER, two EPA publications on its website contain erroneous information about PFOA: “EPA Questions and Answers About TSCA,” Q8 states: “[Is] … perfluorooctanoic acid...