- The PPWR includes sustainability and labelling requirements across the entire packaging life cycle, from production to use and waste management.
- The European Commission has recently released FAQs and implementation guidance to clarify key aspects of PPWR compliance ahead of the 12 August 2026 application date.
- Businesses placing packaging on the EU
Toxic Substances Control Act in Transition: EPA, Courts, and Congress Race to Define TSCA’s Future
As EPA works to finalize a new existing chemicals risk evaluation framework rule, pending Fifth Circuit decisions and legislation introduced to amend TSCA could complicate the Agency’s plans.
By Julia A. Hatcher, Tom Lee, and Hunter J. Kendrick
For the third time since the Toxic Substances Control Act (TSCA) Section 6 was amended in 2016 to mandate existing chemical risk evaluations, the US Environmental Protection Agency (EPA or the Agency) is working to finalize a new iteration of
FDA Publishes Study on PFAS in Cosmetics
- Based on product listings submitted from 2022 through August 2024 identifying all ingredients in each product, FDA identified 51 PFAS intentionally added as ingredients, which were present in 0.41% of the cosmetic products registered during that period.
- FDA evaluated the safety of the 25 most frequently used PFAS in
UK Government Launches First PFAS Plan to Address and Mitigate Harmful Impacts
- The UK government’s PFAS Plan is built on three pillars: understanding PFAS sources, tackling PFAS pathways, and reducing ongoing exposure.
- Initiatives under the plan focus on increased research, monitoring, and evaluation,
Washington State’s Amended PFAS Rule Restricts New Product Categories and Adds Total Fluorine Threshold
- Any product in excess of the 50 ppm total fluorine threshold is presumed to contain “intentionally added” PFAS and subject to the rule unless this presumption is rebutted with “credible evidence.”
- Washington State’s adoption of a total fluorine threshold breaks from other states that previously adopted total organic fluorine thresholds,
EPA Proposes Exemptions to TSCA PFAS Reporting Rule, New Deadline Extension
With the new proposal, EPA seeks to limit the reporting burden on the chemical industry.
By Julia A. Hatcher, Tom Lee, and Hunter J. Kendrick
On November 10, 2025, the US Environmental Protection Agency (EPA) released its much anticipated proposed changes to what is often referred to as the “8(a)(7) Rule” that requires businesses to report on the manufacture and import of certain per- and polyfluoroalkyl substances (PFAS).1 As the name suggests, the rule derives from
What Lies Ahead for Advanced Plastics Recycling Industry After EPA Withdrawal of Proposed TSCA SNURs?
The proposed rules would have triggered EPA risk reviews and restrictions on the industry.
By Julia A. Hatcher, Jennifer K. Roy, Nolan Fargo, and Bruce M. Johnson
On July 9, 2025, the US Environmental Protection Agency (EPA) withdrew significant new use rules (SNURs) proposed under Section 5 of the Toxic Substances Control Act (TSCA) for 18 chemicals derived from waste plastic feedstocks.1 The 18 chemicals are part of a growing industry referred to as “advanced plastics
EPA Finalizes Rule Requiring Ethylene Oxide (EtO) and Chloroprene Emissions Cuts at Chemical Plants
The rule, covering 218 organic chemical and polymer manufacturing plants, imposes stringent emission limits on six chemicals without exemptions for startup, shutdown, and malfunction.
By Karl Karg, Phil Sandick, and Nate Gelfand-Toutant
On April 9, 2024, the US Environmental Protection Agency (EPA) issued a final rule amending the Clean Air Act New Source Performance Standards (NSPS) that apply to emissions from the Synthetic Organic Chemical Manufacturing Industry (SOCMI). The rule also finalizes amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) that apply to the SOCMI (also called the Hazardous Organic NESHAP or HON) and to Group I and II Polymers and Resins Industries (P&R I and P&R II). Some of these amendments include updates to the maximum available treatment technology (MACT) standards, including those addressing heat exchange systems, storage vessels, and process vents, depending on the source category.
The rule will be effective 60 days after publication in the Federal Register but will likely be challenged.
EPA Proposes New Enforcement Initiative for PFAS
The notice is another step in EPA’s PFAS Strategic Roadmap and emphasizes potential CERCLA enforcement.
By Kegan A. Brown, Gary P. Gengel, Thomas C. Pearce, and Taylor R. West
On January 12, 2023, the US Environmental Protection Agency (EPA) issued a notice to solicit public comments on its National Enforcement and Compliance Initiatives (NECI) for Fiscal Years 2024-2027. The notice proposes a new NECI to address per- and polyfluoroalkyl substances (PFAS) contamination, with a “focus on implementing the commitments to action made in EPA’s 2021-2024 [PFAS] Strategic Roadmap.”[1]
The proposed PFAS NECI emphasizes EPA’s intention to identify and pursue potentially responsible parties for PFAS contamination, including under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).
European Commission Launches Public Consultation on EU Chemicals Legislation
The Commission plans to adopt a proposal for a revised Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals in the last quarter of 2022.
By Joachim Grittmann and Alexander Wilhelm
On 20 January 2022, the European Commission opened a public consultation on revising Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH Regulation). The REACH Regulation entered into force on 1 June 2007 and is to be fundamentally revised under the Commission’s Chemicals Strategy for Sustainability, which forms part of the European Green Deal. Until mid-April 2022, interested parties are encouraged to share their opinions on the most relevant aspects of the REACH Regulation to ensure the goals of the Commission on innovation for safe and sustainable chemicals and a high level of protection of health and the environment.