News & Analysis as of

Reporting Requirements Hazardous Substances

Sheppard Mullin Richter & Hampton LLP

PFAS Questions Every Company Needs to Ask Now: Have any of our products contained PFAS? Do we use PFAS at any of our facilities?

2025 will be a landmark year in the regulation of per- and polyfluoroalkyl substances (“PFAS”), which have been nicknamed “forever chemicals” because of their persistence in the environment. For decades, PFAS have been used...more

Bergeson & Campbell, P.C.

EPA Proposes to Add 16 PFAS and 15 PFAS Categories to the TRI List of Chemicals

The U.S. Environmental Protection Agency (EPA) proposed on October 8, 2024, to add 16 individual per- and polyfluoroalkyl substances (PFAS) and 15 PFAS categories representing more than 100 individual PFAS to the Toxics...more

MG+M The Law Firm

EPA Takes Bold Step to Enhance Public Access to PFAS Data

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On October 2, 2024, the US Environmental Protection Agency (EPA) announced a groundbreaking proposal aimed at combating the pervasive threat of per- and polyfluoroalkyl substances (PFAS), commonly known as “forever...more

Clark Hill PLC

Clark Hill 2024 Automotive & Manufacturing Industry Review: Environment, Energy & Natural Resources

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The Supreme Court’s repeal of Chevron deference and multiple activities regarding per- and polyfluoroalkyl substances (PFAS) were among the significant developments for manufacturers during the first half of 2024....more

BakerHostetler

More PFAS Definitions, More Problems - Using PFAS Definitions to Avoid Pitfalls in Compliance, Contracting, Insurance Coverage and...

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There’s no shortage of laws or regulations governing per- and polyfluoroalkyl substances (PFAS). But how PFAS are defined across federal and state programs is far from consistent....more

Clark Hill PLC

PFAS “Lookback” Reporting: Delayed in the US, Moving Ahead in Canada

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As regulatory activity and litigation concerning per- and polyfluoroalkyl substances (“PFAS”) continue to pick up across the U.S. and around the world, recent developments in North America highlight one of the challenges...more

Jones Day

Federal PFAS Reporting Deadline Extended as Biden Administration Announces New PFAS Strategic Plan

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The White House revealed its latest strategy to address PFAS, and the EPA extended the reporting deadline for its PFAS reporting rule....more

Holland & Knight LLP

A Little Breathing Room for Product Importers: EPA Extends TSCA 8(a)(7) Reporting Deadline

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While product importers were spending the summer poring over the Instructions for Reporting PFAS Under TSCA Section 8(a)(7) (May 2024), the U.S. Environmental Protection Agency (EPA) was working on a Direct Final Rule and...more

Pillsbury - PFAS Observer

EPA Issues Eight-Month Delay of the Reporting Period for the PFAS Reporting Rule under TSCA Section 8(a)(7)

On September 5, the U.S. Environmental Protection Agency (EPA) cut industry a significant break by postponing the reporting period for the one-time reporting rule for per- and polyfluoroalkyl substances (PFAS) under Section...more

BCLP

Possible Reprieve on Federal PFAS Reporting Under TSCA: US EPA Issues Direct Final Rule Extending TSCA PFAS Reporting Deadlines

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Companies subject to the Toxic Substances Control Act (“TSCA”) Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (“PFAS”)—also known as the “TSCA PFAS Reporting...more

Faegre Drinker Biddle & Reath LLP

EPA Extends Deadline to Report on Novel PFAS TSCA Reporting Rule

On September 5, 2024, the Environmental Protection Agency (EPA) finalized a rule providing much needed breathing room for the thousands of companies analyzing their company and supply chains to determine if their products or...more

Beveridge & Diamond PC

EPA Announces 8-Month Delay in Submission Window for TSCA PFAS Reporting Rule

The U.S. Environmental Protection Agency (EPA) is modifying the Toxic Substances Control Act (TSCA) regulation imposing reporting and recordkeeping requirements for perfluoroalkyl and polyfluoroalkyl substances (the Rule) to...more

Kelley Drye & Warren LLP

EPA Delays TSCA PFAS Reporting Period Until July 2025

The U.S. Environmental Protection Agency (“EPA” or ​“the Agency”) has announced that it is delaying the reporting period for its controversial per- and polyfluoroalkyl substances (“PFAS”) disclosure rule eight months, with...more

McGuireWoods LLP

Contaminants Compass: September 2024 Edition

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“Contaminants Compass” is a monthly newsletter that provides updates, legal observations and actionable tips to navigate the evolving legal challenges of per- and polyfluoroalkyl substances (PFAS). This edition discusses how...more

Shipman & Goodwin LLP

Required Historical PFAS Reporting Poses Risks Going Forward

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The U.S. Environmental Protection Agency recently established a one-time per- and polyfluoroalkyl substances reporting rule pursuant to the federal Toxic Substances Control Act. Pursuant to the rule, most companies that...more

Alston & Bird

PFAS Primer Quarterly Update: 2024 Q2 – Setting the PFAS Standard

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In the latest edition of the PFAS Primer Quarterly Update, our roundup of regulatory, litigation, and scientific actions involving PFAS, the EPA announces drinking-water regulations, states continue to fight firefighting...more

Baker Donelson

PFOA and PFOS Are Now Hazardous Substances Under CERCLA

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The EPA has designated two per- and polyfluoroalkyl substances (PFAS) – perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), including their salts and structural isomers – as hazardous substances under the...more

Holland & Knight LLP

Product Importers: Are You Ready for the New PFAS Reporting Requirements Under TSCA?

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The U.S. Environmental Protection Agency (EPA) published a far-reaching and important final rule (Rule) on Oct. 11, 2023, requiring comprehensive reporting of per- and polyfluoroalkyl substances (PFAS) manufactured and...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Release Reporting/CERCLA Enforcement: U.S. Environmental Protection Agency and Xenia, Ohio Food Facility Enter into Consent...

The United States Environmental Protection Agency (“EPA”) and Bob Evans Farms, Inc. entered into a June 6th Consent Agreement and Final Order (“CAFO”) addressing an alleged violation of the Comprehensive Environmental...more

Fox Rothschild LLP

EPA Incorporates Seven New PFAS into the Toxics Release Inventory Reporting List

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The United States Environmental Protection Agency (EPA) issued a final rule on May 17, 2024, updating the list of chemicals subject to reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA) and the...more

Integral Consulting Inc.

Big Changes to Maine’s Reporting Requirements and PFAS Phase-Out

In April, Maine’s Governor Mills signed into law Public Law c. 630, An Act to Support Manufacturers Whose Products Contain Perfluoroalkyl and Polyfluoroalkyl Substances (LD 1537, 131st Legislature (S.P. 610 - L.D. 1537),...more

McNees Wallace & Nurick LLC

USEPA Promulgates PFAS Drinking Water Standards and Designates Two PFAS Substances As Hazardous Substances – What Does It Mean For...

In April, the Environmental Protection Agency (“USEPA”) took two actions regarding per- and polyfluoroalkyl substances (“PFAS”), or so-called “forever chemicals,” that could have far-ranging implications....more

BakerHostetler

Maine Narrows and Delays PFAS Regulation

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Overshadowed by the U.S. Environmental Protection Agency’s (EPA) regulation of PFAS under the Safe Drinking Water Act and its designation of PFOS and PFOA as hazardous substances under CERCLA, Maine’s latest revision to its...more

Quarles & Brady LLP

EPA’s Designation of Certain PFAS as Hazardous Substances Under CERCLA Will Have Wide-Ranging Impacts

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On April 19, 2024, the United States Environmental Protection Agency (EPA) issued a pre-publication final rule and an associated enforcement policy concerning two common types of per-and polyfluoroalkyl substances (PFAS):...more

BCLP

EPA Designates PFOS and PFOA as CERCLA Hazardous Substances

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On April 19, 2024, the United States Environmental Protection Agency (“EPA”) announced that it is designating perfluorooctanoic acid (“PFOA”) and perfluorooctanesulfonic acid (“PFOS”) as Hazardous Substances under the...more

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