News and analysis regarding Lautenberg implementation and related legal and administrative developments

December 22, 2025

OECD Will Hold Webinar on January 15, 2026, on “From Production to End-of-Life: Understanding Fluoropolymers across the Life Cycle”

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...
December 16, 2025

New York Issues Suite of PFAS Response Actions, Including a New Study, Final Guidance, and Draft Policies

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...
December 15, 2025

OECD Publishes Synthesis Report on Understanding Fluoropolymers and Their Life Cycle

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...
December 12, 2025

House Subcommittee Will Hold Hearing to Examine the Impact of the CERCLA Designations for PFOA and PFOS and Potential Policy Responses to Superfund Liability Concerns

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...
December 11, 2025

UN Calls for Input for Thematic Report on PFAS and Human Rights

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...
December 9, 2025

Minnesota Publishes Final PFAS in Products Reporting and Fees Rule

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...
December 8, 2025

Connecticut Order Lists Approved Phrases for July 1, 2026, Labeling Requirement

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...
November 21, 2025

TSCA PFAS Reporting: Implications of EPA’s New Statutory Interpretation on Articles

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...
November 17, 2025

EPA Extends Postponement of Effective Date of Certain Provisions of Final TCE Risk Management Rule

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,...
November 14, 2025

Senate Committee Will Hold Hearing to Examine the Future of PFAS Cleanup and Disposal Policy

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.