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January 5, 2024

Forecast for U.S. Federal and International Chemical Regulatory Policy 2024

Bergeson & Campbell, P.C.

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Bergeson & Campbell, P.C. (B&C®) and its global consulting affiliate The Acta Group (Acta®) and consortia management affiliate B&C® Consortia Management, L.L.C. (BCCM) are delighted to share with you our Forecast 2024. 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 Year. Given the global state of play, speculating on how things will shake out in 2024 is challenging.

In an election year, competing priorities will dominate the U.S. Environmental Protection Agency’s (EPA) actions. EPA will understandably wish to complete as many actions on its agenda as possible while tempering its expectations as necessary to avoid any significant pre-election missteps. While there is no consensus on whether the Biden-Harris Administration’s commitment to consequential policy shifts in chemical management has elicited the results promised, reasonable people will agree that the Administration tried hard to fulfill campaign promises in a political climate that is hyperpolarized if not broken entirely. Similarly, reasonable people will disagree on whether the Administration’s chemicals management policies have achieved enhanced environmental and human health protection, greater environmental equity, and a clearer sense of what scientific integrity looks like. These are tough issues to navigate under the best of circumstances, but the devil is in the details and for those of us laser-focused on the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and global chemical governance issues, much work remains to be done.

Internationally, the European Union’s (EU) commitment to net-zero global warming emissions by 2050 advances, but its own election cycle invites significant uncertainty on the policy trajectory in 2024. The EU’s proposed per- and polyfluoroalkyl substances (PFAS) regulation has captivated the world’s attention as, if implemented as proposed, it will be exceedingly consequential. Further progress will be made in 2024 as the EU and United Kingdom (UK) continue to manage Brexit consequences and the evolution of chemical governance programs globally picks up steam, making up for lost time due to the pandemic. Federal elections in the fall in Canada also invite an element of added uncertainty.

We offer you our very best wishes for good health, happiness, and success in the New Year.

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