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The Minnesota Pollution Control Agency (MPCA) held a webinar on February 26, 2026, on its currently unavoidable use (CUU) rule concepts. Under Minnesota’s per- and polyfluoroalkyl substances (PFAS) statute, beginning January 1, 2032, intentionally added PFAS in almost all products will be prohibited in Minnesota unless MPCA issues a CUU determination for the use of the PFAS. MPCA has posted a recording of the webinar, presentation slides, and a summary of the draft rule concepts. Comments on...

This week, I had the pleasure of speaking with my colleagues, Carla N. Hutton, Senior Regulatory Analyst for B&C, and Lindsay A. Holden, Ph.D., DABT, Senior Toxicologist/Regulatory Scientist for B&C and The Acta Group (Acta®), our consulting affiliate. We discuss the relentless pace of state per- and polyfluoroalkyl substances (PFAS) regulations. For those expecting a slowdown, think again. Perhaps in response to perceived inaction at the federal level, over half the states are...

The Minnesota Pollution Control Agency (MPCA) announced on February 28, 2026, that it has updated the online system for reporting products containing intentionally added per- and polyfluoroalkyl substances (PFAS), the PFAS Reporting and Information System for Manufacturers (PRISM). Manufacturers or their representatives will use PRISM to report on intentionally added PFAS in products sold in Minnesota by July 1, 2026. According to MPCA’s website, PRISM 1.1 includes: Additional chemicals; Open...

Perhaps in response to perceived inaction at the federal level, over half of the U.S. states are engaged in per- and polyfluoroalkyl substances (PFAS) notification and restriction regulations. Bergeson & Campbell, P.C.’s (B&C®) All Things Chemical® podcast will cover the relentless pace of state PFAS regulation on the March 12, 2026, episode. B&C’s Lindsay A. Holden, Ph.D., DABT, Senior Toxicologist, and Carla N. Hutton, Senior Regulatory Analyst, join Managing Partner Lynn L....

The California Department of Toxic Substances Control (CDTSC) released on February 25, 2026, a draft Product-Chemical Profile for Floor Maintenance Products Containing Perfluoroalkyl or Polyfluoroalkyl Substances (PFAS) (draft Profile) for public comment. The draft Profile states that PFAS “are a large class of manufactured chemicals with at least one fully fluorinated carbon atom.” The draft Profile notes that all PFAS are Candidate Chemicals under the Safer Consumer Products (SCP) Program...

Before the New Mexico Environmental Improvement Board (NMEIB) began its hearing on February 23, 2026, on the New Mexico Environment Department’s (NMED) proposed rule to implement the Per- and Polyfluoroalkyl Substances (PFAS) Protection Act, NMED posted clean and redline versions of a “Rebuttal Proposed New Rule.” As reported in our January 23, 2026, blog item, NMED posted a revised proposed rule in January 2026. The February 2026 revisions state that the label shall include the symbol of...

On February 18, 2026, the New Mexico legislature passed House Joint Memorial 3, requesting that the New Mexico Environmental Improvement Board (NMEIB) and the New Mexico Environment Department (NMED) provide a report on the implementation of the 2025 Per- and Polyfluoroalkyl Substances (PFAS) Protection Act and recommendations to improve consumer protections from PFAS. Passed less than a week before NMEIB’s February 23, 2026, hearing on NMED’s proposed rule implementing the Act, House Joint...

Recent headlines have declared that the Olympics have “banned PFAS,” with athletes reportedly disqualified after testing revealed the presence of so-called “forever chemicals” on their equipment. The reality is more nuanced, and that nuance matters. The policy at issue does not originate with the International Olympic Committee (IOC), but with the International Ski Federation (FIS), which governs ski and snowboard competitions under its International Competition Rules (ICR). FIS has...

Safer States released on February 18, 2026, its 2026 Analysis of State Policy Addressing Toxic Chemicals and Plastics. According to Safer States, in 2026, at least 15 major state laws and regulations are taking effect, while 33 states are expected to consider at least 275 policies addressing toxic chemicals and plastics. The 15 laws and regulations taking effect this year include broad restrictions on per- and polyfluoroalkyl substances (PFAS) in consumer products, “first-in-the-nation bans on...

Richard E. Engler, Ph.D., To Speak On TSCA New Chemicals At GlobalChem 2026 Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®), will be joined by Shari Barash, Director of the New Chemicals Division, Office of Pollution Prevention and Toxics (OPPT), U.S. Environmental Protection Agency (EPA), and Caroline Tuckhorn, Associate Director, Chemical Management, American Chemistry Council (ACC), topresent “TSCA New Chemicals: Trends, Challenges, and...

The U.S. Environmental Protection Agency (EPA) announced on February 6, 2026, a list of significant actions that the Agency has taken in the first year of the Trump Administration to combat risks from per- and polyfluoroalkyl substances (PFAS) contamination and Make America Healthy Again. EPA notes that it plays a key role in responding to PFAS contamination using its scientific expertise and existing environmental authorities. EPA states that working under several federal laws, it...

Environment and Climate Change Canada (ECCC) announced on February 2, 2026, that it fined Estee Lauder Cosmetics Ltd. $750,000 for two violations of the Canadian Environmental Protection Act, 1999 (CEPA). ECCC states that the offences were related to the failure to inform the government regarding a significant new activity and the failure to comply with a compliance order. In addition to the fine, the Ontario Court of Justice ordered the Company to notify its shareholders about the conviction....

The Minnesota Pollution Control Agency (MPCA) announced on January 30, 2026, that the online system for reporting products containing intentionally added per- and polyfluoroalkyl substances (PFAS), the PFAS Reporting and Information System for Manufacturers (PRISM), is now available. Manufacturers or their representatives will use PRISM to report on intentionally added PFAS in products sold in Minnesota by July 1, 2026. MPCA notes that all information will be available to the...

On January 16, 2026, the New Mexico Environment Department (NMED) posted docket materials related to the New Mexico Environmental Improvement Board’s (NMEIB) February 23, 2026, rulemaking hearing on per- and polyfluoroalkyl substances (PFAS) in consumer products. The materials include clean and redline versions of a revised proposed rule. The revisions would: Exempt pesticides regulated under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) from the reporting and prohibition...

B&C, Acta, And BCCM Publish 2026 Forecast For U.S. Federal And International Chemical Regulatory Policy  Bergeson & Campbell, P.C. (B&C®), its global consulting affiliate The Acta Group (Acta®), and consortia management affiliate B&C® Consortia Management, L.L.C. (BCCM) are pleased to share with you our Forecast 2026. Our distinguished global team of chemical experts worked hard to summarize our collective best guess on what to expect in the New Year regarding global...

Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are pleased to announce that Christine M. Palermo, Ph.D., DABT has joined our firms as Director of Regulatory Sciences. Dr. Palermo provides Acta clients with global strategy in chemical regulatory compliance, risk assessment, and product stewardship, assisting clients to commercialize new products and expand markets for existing product portfolios. Dr. Palermo deploys the extensive domestic and international experience she...

On January 6, 2026, comments by Lynn L. Bergeson were featured in Chemical & Engineering News's article regarding the U.S. Environmental Protection Agency's (EPA) move to roll back limits on certain per- and polyfluoroalkyl substances (PFAS) in drinking water while state efforts to regulate PFAS show no signs of slowing down. The EPA is also working to roll back some PFAS reporting requirements under the Toxic Substances Control Act, reporting that was called for in a 2023 rule...

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...

Download a PDF of the Forecast 2026. Bergeson & Campbell, P.C. (B&C®), its global consulting affiliate The Acta Group (Acta®), and consortia management affiliate B&C® Consortia Management, L.L.C. (BCCM) are pleased to share with you our Forecast 2026. Our distinguished global team of chemical experts worked hard to summarize our collective best guess on what to expect in the New Year regarding global industrial, agricultural, and biocidal chemical regulatory and policy...

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...

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...

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...

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, empowering women, children, and families to rebuild their lives and heal from trauma, abuse, and houselessness, in lieu of gifts to our clients, and on our clients’ behalf. B&C, Acta, And BCCM To Publish Forecast 2026 Start 2026 with the information you need --...

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...

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...

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...

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 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 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 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...

The New Mexico Environment Department (NMED) has posted frequently asked questions (FAQ) regarding New Mexico’s Per- and Polyfluoroalkyl Substances (PFAS) Protection Act labeling requirements. As reported in our October 15, 2025, memorandum, NMED petitioned New Mexico’s Environmental Improvement Board (EIB) to adopt a proposed rule to implement the PFAS Protection Act, including labeling requirements, and EIB voted to proceed with the rulemaking during its October 24, 2025, meeting....

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,...

Download transcript. A few months ago, I recorded a podcast with my colleagues, Carla N. Hutton, Senior Regulatory Analyst for B&C, and Dr. Richard E. Engler, Director of Chemistry for B&C and The Acta Group (Acta®), our consulting affiliate, on the ever-expanding and complicated scope of per- and polyfluoroalkyl substances (PFAS) regulation in the United States. We convened a webinar on this topic in mid-May that attracted a record-breaking 1000+ registrants, suggesting to us that...

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...

Following up on the New Mexico Environment Department’s (NMED) September 25, 2025, webinar on a labeling requirement for products containing intentionally added per- and polyfluoroalkyl substances (PFAS), NMED announced on October 8, 2025, that it has petitioned New Mexico’s Environmental Improvement Board (EIB) to adopt a proposed rule to implement the PFAS Protection Act. According to NMED’s press release, the proposed rule would “implement the full scope of the PFAS Protection Act,...

The New Mexico Environment Department (NMED) has posted a Public Involvement Plan (PIP) for implementing the Per- and Polyfluoroalkyl Substances (PFAS) Protection Act (HB 212). Effective October 8, 2025, the PIP provides public participation opportunities and information needed for the community to engage in rulemaking, enforcement, and policy development under the Act. The PIP also identifies information about affected communities and resources needed by NMED to incorporate public participation...

The U.S. Environmental Protection Agency (EPA) announced on October 7, 2025, the addition of a per- and polyfluoroalkyl substance (PFAS) to the list of chemicals covered by the Toxics Release Inventory (TRI). EPA added sodium perfluorohexanesulfonate (PFHxS-Na) to the TRI list pursuant to the Fiscal Year 2020 National Defense Authorization Act (NDAA). EPA states that the addition is due to EPA issuing a final toxicity value in 2025 entitled “IRIS Toxicological Review of Perfluorohexanesulfonic...

Beginning July 1, 2026, Connecticut will prohibit the manufacture, sale, and distribution of certain consumer products that contain intentionally added per- and polyfluoroalkyl substances (PFAS) unless the manufacturer provides prior notification to the Connecticut Department of Energy and Environmental Protection (DEEP) and labels these products. The consumer products are apparel; carpets or rugs; cleaning products; cookware; cosmetic products; dental floss; fabric treatments; children's...

As reported in our May 29, 2025, memorandum, on May 22, 2025, the Minnesota Pollution Control Agency (MPCA) held a public hearing on its proposed per- and polyfluoroalkyl substances (PFAS) reporting rule. Administrative Law Judge (ALJ) Jim Mortenson facilitated the hearing. To allow the proposed rule to move forward, the ALJ must conclude that MPCA has the legal authority to adopt the rule; that MPCA has fulfilled all relevant legal and procedural requirements to promulgate the rules; and that...

On September 19, 2025, comments by Catherina D. Narigon, Associate with B&C, were featured in Inside EPA's article regarding perfluoroalkyl and polyfluoroalkyl substances (PFAS) reporting waivers. Catherina Narigon, an associate with industry law firm Bergeson & Campbell, believes EPA will still impose some reporting requirements that industry may find burdensome. “My gut feeling is EPA will come out with revisions that are more conservative than what businesses may want,” Narigon...

As reported in our April 11, 2025, memorandum, on April 8, 2025, New Mexico Governor Michelle Lujan Grisham (D) signed the Per- and Poly-Fluoroalkyl Substances (PFAS) Protection Act (HB 212), which will phase out intentionally added PFAS in certain consumer products before banning intentionally added PFAS in most products on January 1, 2032. The Act also requires manufacturers to report information about intentionally added PFAS by January 1, 2027. The Act states that the New Mexico...

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,...

On September 4, 2025, the Office of Management and Budget (OMB) published the Trump Administration’s Spring 2025 Unified Agenda. The U.S. Environmental Protection Agency’s (EPA) Unified Agenda includes the following rulemakings regarding per- and polyfluoroalkyl substances (PFAS): PFAS Requirements in National Pollutant Discharge Elimination System (NPDES) Permit Applications: EPA notes that the list of pollutants in the NPDES application regulations has not been updated since 1987 and...

On August 25, 2025, the New York State Department of Environmental Conservation (NYS DEC) held a pre-rulemaking stakeholder meeting on its implementation of New York’s per- and polyfluoroalkyl substances (PFAS) in apparel law. Section 37-0121 of the Environmental Conservation Law (ECL) prohibits the sale of apparel containing PFAS as intentionally added chemicals beginning January 1, 2025. No later than January 1, 2027, Section 37-0121 prohibits the sale of apparel containing PFAS at or above...