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

January 15, 2026

EPA Completes Risk Evaluation for Five Phthalates, Intends to Regulate “Dozens” of COUs

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,...
January 12, 2026

EPA Requests Nominations for Panel Members and Ad Hoc Reviewers for SACC

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...
January 9, 2026

EPA Intends to Notify Companies Beginning in Spring 2026 of Expiring TSCA Claims

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...
January 6, 2026

FDA Finds “Significant Data Gaps” for PFAS Used in Cosmetic Products

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...
December 24, 2025

EPA Announces Accelerated Crackdown on Toxic and Poisonous Imports

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...
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...