All Knowledge & Insights By Date

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...

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 Wednesday, November 5, 2025, the Supreme Court of the United States heard arguments on executive tariff authority, a case that promises to have ripple effects far beyond the bounds of pure trade law. Trump v. V.O.S. Selections, Inc., No. 25-250. In the chemical sector -- where global chemical feedstocks, complex supply chains, and regulatory compliance are already famously complicated -- the stakes are especially high. If the Court limits or invalidates the President’s ability unilaterally...

On October 29, 2025, the Senate Committee on Environment and Public Works favorably reported several nominations, including Jeffrey Hall to be an Assistant Administrator for the Office of Enforcement and Compliance Assurance (OECA) at the U.S. Environmental Protection Agency (EPA) and Douglas Troutman to be Assistant Administrator for Toxic Substances at EPA, each by a vote of ten to nine along party lines. The Committee considered Hall’s nomination during a July 23, 2025, hearing, during...

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...

As the federal government endures another prolonged shutdown, uncertainty is rippling through every agency, with the impact clearly visible at the U.S. Environmental Protection Agency (EPA). With only a fraction of staff on duty and most routine operations halted, the chemical and pesticide regulatory landscape faces a new round of challenges in both the Office of Pollution Prevention and Toxics (OPPT) and the Office of Pesticide Programs (OPP). EPA’s September 29, 2025, contingency plan...

On October 23, 2025, the Environment and Public Works Chemical Safety, Waste Management, Environmental Justice, and Regulatory Oversight Subcommittee will hold a hearing on “Examining the Beneficial Use and Regulation of Chemicals.” The Committee is scheduled to hear from the following witnesses: Peter Huntsman, President and Chief Executive Officer (CEO), Huntsman Corporation; Dr. Gwen Gross, Senior Technical Fellow, The Boeing Company; and Dr. Tracey Woodruff, Professor and Director,...

On October 17, 2025, comments by James V. Aidala and Richard E. Engler, Ph.D., were featured in Bloomberg Law's article regarding the U.S. Environmental Protection Agency's (EPA) recent completion of more than 3,000 corporate notices about chemicals' substantial risks. The corporate notices can give the EPA its first sign that a substance could be dangerous. They stem from the Toxic Substances Control Act’s requirement that chemical manufacturers, importers, processors, and distributors...

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,” on October 30, 2025, from 11:00 a.m. - 12:00 p.m. (EDT). This complimentary webinar will explore the background and current status of the U.S. Environmental Protection Agency’s (EPA) precedent-setting review of seven phthalates under Toxic Substances Control Act...

On Sept. 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). When conducting a TSCA existing chemical risk evaluation, EPA must determine whether a chemical substance presents an unreasonable risk of injury to health or the environment, without considering costs or non-risk factors under the conditions of use (COU). As...