All Knowledge & Insights By Date

The European Union Deforestation Regulation (EUDR) appears to be headed for yet another full-year delay following growing political pressure, concerns about the readiness of the European Commission’s (EC) information technology (IT) systems, and intensifying industry warnings that the current December 30, 2025, compliance deadline is becoming increasingly unrealistic. While the EC has not yet officially postponed the implementation date, the signals coming out of Brussels are clear that an...

On Thanksgiving Eve, November 26, 2025, the White House Office of Science and Technology Policy (OSTP) requested input from interested parties on federal policy updates “that aim to accelerate the American scientific enterprise, enable groundbreaking discoveries, and ensure that scientific progress and technological innovation benefit all Americans.” 90 Fed. Reg. 54412. OSTP states that “[t]hrough this Request for Information (RFI), OSTP seeks input from academia; private sector...

On November 24, 2025, the U.S. Environmental Protection Agency (EPA) released the key default values that it uses in its risk assessments of new chemicals under the Toxic Substances Control Act (TSCA). EPA is making the assumptions available on its website in the New Chemicals Division Reference Library. EPA states that it expects the publication of the default values “to improve efficiency, reducing the likelihood that submissions need to be reworked or resubmitted.” According to EPA,...

On November 19, 2025, the U.S. Environmental Protection Agency (EPA) announced the availability of and requested comment on a draft risk evaluation under the Toxic Substances Control Act (TSCA) for 1,2-dichloroethane (Chemical Abstracts Service Registry Number® (CAS RN®) 107-06-2, also known as ethylene dichloride or EDC). 90 Fed. Reg. 52054. EPA notes that the purpose of risk evaluations under TSCA is to determine whether a chemical substance presents an unreasonable risk of injury to health...

Register Now For “31st Annual Green Chemistry Challenge Awards: New Categories and Expanded Opportunities,” December 4, 2025, 11:00 a.m. - 12:00 p.m. (EST), via webinar Bergeson & Campbell, P.C. (B&C®) and the American Chemical Society (ACS) are pleased to present “31st Annual Green Chemistry Challenge Awards: New Categories and Expanded Opportunities.” During this webinar, Richard E. Engler, Ph.D., Director of Chemistry at B&C and former leader of the U.S. Environmental...

The state of Oregon’s packaging and paper Extended Producer Responsibility (EPR) program, enacted in 2021, has progressed into its enforcement stage. With the first fee obligations and real-world compliance deadlines now in place, the risk of litigation under and against the program has transitioned from theoretical to real. In July 2025, a major trade association, National Association of Wholesaler-Distributors (NAW), filed a constitutional challenge to Oregon’s law, raising issues that are...

On November 13, 2025, the U.S. Environmental Protection Agency (EPA) issued a proposed rule to amend the Toxic Substances Control Act (TSCA) Section 8(a)(7) regulation for reporting and recordkeeping requirements for perfluoroalkyl and polyfluoroalkyl substances (PFAS). 90 Fed. Reg. 50923. As reported in our October 3, 2023, memorandum, the final rule requires manufacturers (including importers) of PFAS and PFAS-containing articles in any year since 2011 through 2022 to report information...

On October 23, 2025, the Senate Environment and Public Works Subcommittee on Chemical Safety, Waste Management, Environmental Justice, and Regulatory Oversight held a hearing on “Examining the Beneficial Use and Regulation of Chemicals.” The Subcommittee heard from the following witnesses: Peter Huntsman, President and Chief Executive Officer (CEO), Huntsman Corporation (written testimony); Dr. Gwen Gross, Senior Technical Fellow, The Boeing Company (written testimony); and Dr. Tracey...

Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are pleased to announce that Ryan N. Schmit has joined our firms. A 15-year veteran of the U.S. Environmental Protection Agency’s (EPA) Office of Chemical Safety and Pollution Prevention (OCSPP), Mr. Schmit worked on the front lines of EPA’s Toxic Substances Control Act (TSCA) implementation efforts, including significant and precedent-setting policy matters regarding the establishment of TSCA procedural frameworks; new...

On October 14, 2025, the Australia Industrial Chemicals Introduction Scheme (AICIS) announced that it has initiated an evaluation on the introduction and use of per- and polyfluoroalkyl substances (PFAS) in Australia under Section 74 of the Industrial Chemicals Act 2019 (IC Act). According to AICIS, the evaluation will review the 522 PFAS listed on the Australian Inventory of Industrial Chemicals. The evaluation will confirm whether the listed PFAS have been introduced in Australia, and if so,...

Register Now For “Phthalate Risk Evaluation under TSCA and the Potential Impacts to the Plastics Industry,” October 30, 2025, 11:00 a.m. – 12:00 p.m. (EDT) Bergeson & Campbell, P.C. (B&C®), The Acta Group (Acta®), and B&C® Consortia Management, L.L.C. (BCCM) are pleased to present “Phthalate Risk Evaluation under TSCA and the Potential Impacts to the Plastics Industry,” a complimentary webinar exploring the background and current status of the U.S. Environmental...

On September 23, 2025, the U.S. Environmental Protection Agency (EPA) proposed highly anticipated amendments to the procedural framework rule for conducting existing chemical risk evaluations under the Toxic Substances Control Act (TSCA). 90 Fed. Reg. 45690. When conducting an existing chemical risk evaluation under TSCA, EPA must determine whether a chemical substance presents an unreasonable risk of injury to health or the environment, without considering costs or nonrisk factors, including...

FIFRA Fundamentals, September 24-25, 2025, via webinar Bergeson & Campbell, P.C. (B&C®) and Chemical Watch are pleased to present FIFRA Fundamentals, a two-day course taught by professionals from B&C’s renowned Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) team. Lisa R. Burchi, Of Counsel; Heather F. Collins, M.S., Regulatory Consultant; Dana S. Lateulere, Regulatory Consultant; and Meibao Zhuang, Ph.D., Senior Scientist/Regulatory Consultant, will share legal,...

Perfluoroalkyl and polyfluoroalkyl substances (PFAS) are attracting global legal, regulatory, commercial, and litigation attention as no other “emerging contaminant” has. Companies producing, processing, distributing, and/or using these substances must be aware of global legal and scientific developments and take steps now to minimize legal, regulatory, and commercial risk. Bergeson & Campbell, P.C. (B&C®) and its global consulting affiliate The Acta Group (Acta®) have prepared...

Bergeson & Campbell, P.C. (B&C®) is pleased to share details with clients and friends about these premiere conferences and trainings in September and October, during which B&C professionals will present valuable and actionable information covering plastics waste and recycling, per- and polyfluoroalkyl substances (PFAS) regulations, Toxic Substances Control Act (TSCA) developments, and Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) issues. Environmental Regulation in...

Microplastics are, in recent years, at the forefront of regulatory and policy driven conversations across the United States. Regulatory measures to address microplastics at both state and federal levels have been introduced with increasing frequency. This trend holds true in 2025, which has already seen a significant quantity of legislative, regulatory, and policy proposals and actions in the microplastics sphere. Ongoing interest in microplastics and regulations suggests continued increases in...

The European Chemicals Agency (ECHA) announced on August 20, 2025, that it published an updated proposal to restrict per- and polyfluoroalkyl substances (PFAS) under the European Union’s (EU) Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation. The authorities from Denmark, Germany, the Netherlands, Norway, and Sweden (Dossier Submitters) submitted the initial proposal in January 2023 and have now completed their evaluation of more than 5,600 scientific and...

On August 15, 2025, Illinois Governor JB Pritzker (D) signed a bill (HB 2516) amending the PFAS Reduction Act to ban certain consumer products containing intentionally added per- and polyfluoroalkyl substances (PFAS). As of January 1, 2032, intentionally added PFAS are banned in cosmetics, dental floss, juvenile products, menstrual products, and intimate apparel. The Act defines PFAS as “a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom.” The bill...

Lynn L. Bergeson And Richard E. Engler, Ph.D. To Present On Chemical Issues At Regulatory Summit North America Bergeson & Campbell, P.C. (B&C®) affiliate The Acta Group (Acta®) is a proud sponsor of Chemical Watch’s Regulatory Summit North America 2025, a four day conference providing a comprehensive overview of developments in chemicals control legislation, chemicals management for electronics, per- and polyfluoroalkyl substances (PFAS), and product sustainability. Richard E....

2025 has been a busy year for extended producer responsibility (EPR) policy, especially for packaging and paper products. States have enacted new EPR programs and laws to assess the need for EPR. Existing programs have been altered or updated. Compliance deadlines have come and gone. EPR legislation has been introduced in many states. With so many moving parts, the status of EPR in the United States can be hard to follow. Bergeson & Campbell, P.C. (B&C) provides the following overview of...

Register Now For “Regulation Without Borders: The EUDR and the New Era of Global Due Diligence,” August 5, 2025, 10:00 a.m. – 11:15 a.m. (EDT) Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®); EPPA; and Preferred by Nature (PBN) are pleased to present “Regulation Without Borders: The EUDR and the New Era of Global Due Diligence,” a complimentary webinar providing a detailed exploration of the European Union Deforestation Regulation (EUDR) and how it applies to...

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 prohibited in Maine on January 1, 2026, were due June 1, 2025. The agenda for the July 17, 2025, meeting of the Maine Board of Environmental Protection (MBEP) includes a proposed amendment to Chapter 90: Products Containing PFAS. According to the Maine Department of...

On June 25, 2025, Bergeson & Campbell, P.C. (B&C®), the Environmental Law Institute (ELI), and the George Washington University (GWU) Milken Institute School of Public Health presented “TSCA Reform -- Nine Years Later.” This virtual conference marked the ninth Toxic Substances Control Act (TSCA) Annual Conference, reflecting on the accomplishments and challenges since the implementation of the 2016 Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg Act) and...

Register Now For “TSCA Reform – Nine Years Later” Virtual Conference, 8:30 a.m. – 4:30 p.m. (EDT), June 25, 2025 Complimentary registration is now open for this dynamic virtual conference providing updates and insights regarding the current state of Toxic Substances Control Act (TSCA) implementation, ongoing and emerging issues, and related developments. As with our previous TSCA anniversary events, a stellar faculty of speakers from government, non-governmental organizations, industry,...

The Council of the European Union (EU) announced on June 12, 2025, that it reached a provisional agreement with the European Parliament (EP) on the “one substance, one assessment” (OSOA) legislative package, “which aims to streamline assessments of chemicals across relevant EU legislation, strengthen the knowledge base on chemicals, and ensure early detection and action on emerging chemical risks.” The package contains three proposals: a directive concerning the re-attribution of...

On May 27, 2025, President Trump signed an Executive Order (EO) on “Restoring Gold Standard Science.” 90 Fed. Reg. 22601. The EO states that the Trump Administration “is committed to restoring a gold standard for science to ensure that federally funded research is transparent, rigorous, and impactful, and that Federal decisions are informed by the most credible, reliable, and impartial scientific evidence available.” The EO restores the scientific integrity policies of the first Trump...

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 Mortenson facilitated the hearing, which had more than 100 participants in attendance. MPCA has made available online the PowerPoint document used for the hearing presentation, the hearing exhibits, and a transcript of the hearing. Procedural Background The pre-hearing public...

For complimentary registration, visit the ELI registration page:https://www.eli.org/events/tsca-reform-nine-years-later Bergeson & Campbell, P.C. (B&C®), the Environmental Law Institute (ELI), and the George Washington University Milken Institute School of Public Health are pleased to present “TSCA Reform -- Nine Years Later” on June 25, 2025. This complimentary virtual conference marks the ninth Toxic Substances Control Act (TSCA) Annual Conference. As with our previous TSCA...

Save The Date For “TSCA Reform – Nine Years Later” On June 25, 2025 Save the date to join Bergeson & Campbell, P.C. (B&C®), the Environmental Law Institute (ELI), and the George Washington University Milken Institute School of Public Health for our ninth annual conference providing updates and insights regarding the current state of Toxic Substances Control Act (TSCA) implementation, ongoing and emerging issues, and related developments. As with our previous TSCA anniversary...

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 substances (PFAS) under the Toxic Substances Control Act (TSCA). Under the interim final rule, the data submission period would begin April 13, 2026, and end October 13, 2026. Small manufacturers reporting exclusively as article importers would have until April 13, 2027, to report....

On April 28, 2025, the U.S. Environmental Protection Agency (EPA) outlined upcoming Agency action to address per- and polyfluoroalkyl substances (PFAS). According to EPA’s announcement, “[i]n line with Administrator Zeldin’s Powering the Great American Comeback initiative, EPA’s work in this space will advance Pillar 1: Clean Air, Land, and Water for Every American, and Pillar 3: Permitting Reform, Cooperative Federalism, and Cross-Agency Partnership.” EPA states that these actions...

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 (MPCA) published a proposed rule intended to clarify the reporting requirements, specify how and what to report, and establish fees. Written comments on the proposed rule are due May 21, 2025, at 4:30 p.m. (CDT). On May 22, 2025, at 2:00 p.m. (CDT), MPCA will hold a public...

Register Now For “PFAS Updates: What’s Happening in the U.S. and EU,” May 13, 2024, 11:00 a.m. – 12:00 p.m. (EDT), Via Webinar Register now to join Bergeson & Campbell, P.C. (B&C®) affiliate The Acta Group (Acta®) and EPPA for “PFAS Updates: What’s Happening in the U.S. and EU,” a complimentary webinar offering expert updates on per- and polyfluoroalkyl substances (PFAS) regulatory developments. During this webinar, Meglena Mihova, Managing Partner, EPPA, and Richard E....

On April 8, 2025, New Mexico Governor Michelle Lujan Grisham (D) signed the Per- and Poly-Fluoroalkyl Substances (PFAS) Protection Act (HB 212). Like Minnesota and Maine, New Mexico will begin phasing out certain consumer products containing intentionally added PFAS, defining PFAS as “a substance in a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom.” In 2032, New Mexico will prohibit products containing intentionally added PFAS unless the use of...

On January 21, 2025, the U.S. Environmental Protection Agency’s (EPA) proposed rule seeking to set effluent limitation guidelines for certain per- and polyfluoroalkyl substances (PFAS) under the Clean Water Act (CWA) was withdrawn from Office of Management & Budget (OMB) review following President Trump’s Executive Order implementing a regulatory freeze. Federal action may be halted, but states are beginning to enact legislation that seeks to address PFAS contained in industrial...

On March 5, 2025, Environment and Climate Change Canada (ECCC) announced the availability of its final State of Per- and Polyfluoroalkyl Substances (PFAS) Report (State of PFAS Report) and proposed risk management approach for PFAS, excluding fluoropolymers. The State of PFAS Report concludes that the class of PFAS, excluding fluoropolymers, is harmful to human health and the environment. To address these risks, on March 8, 2025, Canada published a proposed order that would add the class of...

On January 17, 2025, days before the end of President Biden’s term, the U.S. Environmental Protection Agency (EPA) released two new enforcement documents: (1) Expedited Settlement Agreement (ESA) Pilot Program Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (FIFRA Settlement Pilot Program or Pilot Program); and (2) Interim Consolidated Enforcement Response and Penalty Policy (Interim CERPP) for the Toxic Substances Control Act (TSCA) New and Existing Chemicals Program....

ABA And B&C Announce Release Of “Chemical Product Law and Supply Chain Stewardship” Book Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are pleased to announce the release by American Bar Association (ABA) Publishing of Chemical Product Law and Supply Chain Stewardship: A Guide to New TSCA, edited by B&C Managing Partner Lynn L. Bergeson and authored by Ms. Bergeson and members of B&C and Acta’s highly experienced Toxic Substances Control Act (TSCA)...

On March 10, 2025, the U.S. Environmental Protection Agency (EPA) announced its intent to reconsider the May 3, 2024, rule amending the procedural framework rule for conducting risk evaluations under the Toxic Substances Control Act (TSCA) (2024 Risk Evaluation Framework Rule). According to EPA, it will initiate a rulemaking “that will ensure the agency can efficiently and effectively protect human health and the environment and follow the law.” As reported in our February 7, 2025, blog...

ABA And B&C Announce Release Of Chemical Product Law and Supply Chain Stewardship Book Chemical Product Law and Supply Chain Stewardship, edited by Lynn L. Bergeson and published by the American Bar Association (ABA), provides a road map to navigate efficiently the transformational changes in chemical product law, identifies the practical business and product stewardship implications of the new normal in product regulation, and explains the urgent need for supply chain awareness so that the...

On January 16, 2025, the U.S. Environmental Protection Agency (EPA) announced the availability of and requested public comment on the draft scope of the risk evaluation to be conducted under the Toxic Substances Control Act (TSCA) for vinyl chloride. 90 Fed. Reg. 4738. EPA notes that under TSCA, the scope documents must include the conditions of use (COU), hazards, exposures, and the potentially exposed or susceptible subpopulations (PESS) that EPA expects to consider in conducting its risk...

On January 14, 2025, the U.S. Environmental Protection Agency (EPA) issued a proposed rule to address the unreasonable risk of injury to human health presented by Color Index (C.I.) Pigment Violet 29 (PV29) under its conditions of use (COU) as documented in EPA’s January 2021 risk evaluation and September 2022 revised risk determination. 90 Fed. Reg. 3107. The proposed rule states that the Toxic Substances Control Act (TSCA) requires that EPA address by rule any unreasonable risk of injury to...

On January 14, 2025, the U.S. Environmental Protection Agency (EPA) released the final risk evaluation for diisononyl phthalate (DINP) conducted under the Toxic Substances Control Act (TSCA). EPA states that it has determined that DINP presents an unreasonable risk of injury to human health because workers could be exposed to high concentrations of DINP in mist when spraying adhesive, sealant, paint, and coating products that contain DINP. According to EPA, DINP can cause developmental toxicity...

2025 Forecast For U.S. Federal And International Chemical Regulatory Policy On January 6, 2025, Bergeson & Campbell, P.C. (B&C®), The Acta Group (Acta®), and B&C® Consortia Management, L.L.C. (BCCM) published the “Forecast for U.S. Federal and International Chemical Regulatory Policy 2025.” This carefully curated document represents our seasoned team’s collective take on what to expect regarding global industrial, agricultural, and biocidal chemical initiatives in the New...

The U.S. Environmental Protection Agency (EPA) announced on January 13, 2025, that it signed a long-awaited memorandum of understanding (MOU) with the Occupational Safety and Health Administration (OSHA) formalizing coordination on EPA’s work to assess and manage existing chemicals under Section 6 of the Toxic Substances Control Act (TSCA). According to EPA’s press release, “EPA and OSHA anticipate that better coordination under this MOU will result in improved workplace health and safety...

The U.S. Environmental Protection Agency (EPA) released final risk management rules under the Toxic Substances Control Act (TSCA) for trichloroethylene (TCE) and perchloroethylene (PCE) on December 9, 2024, and for carbon tetrachloride (CTC) on December 11, 2024. EPA states that all uses of TCE will be banned over time, with “the vast majority of identified risks eliminated within one year,” and safer alternatives readily available for the majority of uses. The PCE rule will ban manufacture,...

On December 20, 2024, the Maine Department of Environmental Protection (MDEP) published a proposed rule regarding products containing intentionally added per- and polyfluoroalkyl substances (PFAS). The rule would establish criteria for currently unavoidable uses (CUU) of intentionally added PFAS in products and implement sales prohibitions and notification requirements for products containing intentionally added PFAS but determined to be a CUU. MDEP will hold a public hearing on January 16,...

On December 13, 2024, the U.S. Environmental Protection Agency (EPA) published a final Health and Safety Reporting Rule under the Toxic Substances Control Act (TSCA) to require manufacturers (including importers) of 16 chemical substances to submit copies and lists of certain unpublished health and safety studies to EPA. 89 Fed. Reg. 100756. The rule applies to manufacturers in the North American Industrial Classification System (NAICS) codes for chemical manufacturing (NAICS code 325) and...

Bergeson & Campbell, P.C. extends its best wishes to our clients and many friends. We wish you and your family a safe and healthy New Year. As we have for many years, the firm has made a contribution to the House of Ruth, a shelter for battered women and their children, in lieu of gifts to our clients, and on our clients’ behalf. Register Now For “What to Expect in Chemicals Policy and Regulation and on Capitol Hill in 2025,” January 14, 2024, 11:00 a.m. – 12:00 p.m. (EST), Via...