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OSHA Announces Informal Public Hearings on Proposed Deregulatory Actions

By Peter Gould, Cole Wist, Michael Cox and John Rainwater on Posted in Chemicals & Products, Health & Safety, Product Safety
The Occupational Safety and Health Administration (OSHA) recently announced a series of informal public hearings regarding proposed deregulatory actions affecting workplace safety and health standards. The hearings follow proposed rulemakings published in the Federal Register on July 1, 2025 and April 6, 2026. The proposed actions would impact a broad range of OSHA regulations, including … Continue Reading

Navigating Amara’s Law: A Guide to Minnesota’s New PFAS Reporting Obligations

By Lianne Mantione and Abigail Dop on Posted in Chemicals & Products
Manufacturers and distributors around the country are gearing up to comply with Minnesota’s Amara’s Law, which targets the use of intentionally added perfluoroalkyl and polyfluoroalkyl substances (PFAS) in consumer products. The first stage of Amara’s Law took effect in 2025 when eleven categories of new products sold in Minnesota, such as carpets, cookware, dental floss, … Continue Reading

Understanding New Mexico’s New PFAS Product Labeling Requirement

By Danelle Gagliardi and Abigail Dop on Posted in Chemicals & Products
Regulation of per- and polyfluoroalkyl substances (PFAS) in consumer products continues to accelerate across the United States at the state level. In addition to phase-outs and bans on certain consumer products containing PFAS, state regulators are turning to labeling requirements as a tool to drive transparency and liability. One notable recent development comes from New … Continue Reading

UK Parliamentary Committee Publishes Report on PFAS Risks

By Francesca Puttock on Posted in Chemicals & Products, Climate Change & Sustainability, Environmental, Environmental Due Diligence, Food Safety, Food-Contact Materials and Articles, Health & Safety, Supply Chain, Water Quality
It has been a couple of months since the UK PFAS Plan was published and made countless headlines. Today (23 April 2026), having gathered evidence as part of a parliamentary inquiry, the House of Commons’ Environmental Audit Committee (“EAC“) published a report titled ‘Addressing the risks from Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS)‘. The report summarises … Continue Reading

Defra releases anticipated ‘PFAS Plan’

By Francesca Puttock on Posted in Chemicals & Products, Environmental, Food Safety, Food-Contact Materials and Articles, Health & Safety, Supply Chain
Today we published an update on Defra’s PFAS Plan: “UK Government Releases PFAS Plan Teased in December 2025“. This plan features among the commitments made in the Environmental Improvement Plan made public at the end of last year. It is generally recognised that the UK needs a plan for PFAS management, but in the hours … Continue Reading

The EU AI Act and The Automotive Sector: Why Are Product Conformity Regimes Relevant to High-risk AI Systems?

By Nicola Smith, David Naylor and Bartolomé Martín on Posted in Product Safety
Introduction From autonomous-driving to ADAS (Advanced Driver Assistance Systems), to the potential for Artificial Intelligence (AI) to transform the aftermarket, AI is much-discussed as being transformational in the automotive sector; and there are numerous reported examples of AI being used already, for design, validation and performance management, connected with the manufacturing process. However, automotive businesses … Continue Reading

District Court Strikes Down FDA’s LDT Rule, Opens the Door for Challenges to FDA’s Regulation of Other “Services” as Medical Devices

By Squire Patton Boggs on Posted in Chemicals & Products, Environmental Litigation
On Monday, March 31, a court in the Eastern District of Texas found unlawful and vacated the Food and Drug Administration’s 2024 Rule regulating as “devices” under the Food, Drug, and Cosmetic Act FDCA, certain laboratory-developed tests used to diagnose, monitor, or determine treatment for diseases and conditions. The decision, American Clinical Laboratory Assoc. v. FDA, No. … Continue Reading

California Prop 65’s Short-form Warnings Will No Longer Be Short – Summary of Amendments to Short-form Warnings under California Proposition 65 – Effective January 1, 2025 with Three-Year Grace Period

By Squire Patton Boggs on Posted in Chemicals & Products
After what has amounted to a multi-year rulemaking process, the California Office of Environmental Health Hazard Assessment (OEHHA) finalized amendments to the short-form warnings under Proposition 65 on December 6, 2024. The amendments (outlined in full here) require that short-form warnings include at least one chemical name, along with other options for safe harbor warning. … Continue Reading

FDA Announces End of PFAS Use in US Food Packaging

By Lianne Mantione and Charli Davis on Posted in Chemicals & Products, Food Safety
On February 28, 2024, the Food and Drug Administration (“FDA”) published a news release regarding the voluntary market phase-out of per and polyfluoroalkyl substances (PFAS) in grease-proofing substances used on food packaging. The FDA stated that the completion of this phase-out “eliminates the primary source of dietary exposure to PFAS from authorized food contact uses.”… Continue Reading

UK REACH: Awaited Consultation on Policy Direction for Registration of Chemicals

By Francesca Puttock and Molly McKenna on Posted in Brexit, Chemicals & Products, Environmental, Health & Safety, Product Safety
The most anticipated developments for 2024 in UK chemicals regulation are the long-awaited publication of the UK’s Chemicals Strategy, and a consultation on the UK government’s alternative transitional registration model (ATRm). In November 2023, a policy paper was issued outlining the government’s high-level plans for ATRm, but the questions and details for stakeholders are still … Continue Reading

FDA Delays Enforcement of MOCRA Deadlines for Facility Registration and Product Listing to July 1, 2024

By John Wyand, Jennifer Tharp and Jennifer Satterfield on Posted in Chemicals & Products, Rulemaking & Policy Development, Uncategorized
On November 9, 2023, the FDA published notice of final guidance that delays FDA’s enforcement of some facilities’ registration and product listing compliance requirements under MOCRA to July 1, 2024. This enforcement delay applies to facilities that “engaged in manufacturing or processing of a cosmetic product” or products as of MOCRA’s enactment date (December 29, … Continue Reading

Revamping Cosmetics Safety and Regulation: Updates from FDA on Regulatory Changes under MOCRA

By John Wyand, Jennifer Tharp and Jennifer Satterfield on Posted in Chemicals & Products, Rulemaking & Policy Development
In August 2023, the FDA released draft guidance on upcoming regulatory changes pursuant to MOCRA, including guidance on cosmetic product facility registrations and product listings. MOCRA applies to any establishment that manufactures or processes cosmetics products. According to the draft guidance, the FDA is in the process of creating a new online portal for facility … Continue Reading

Windsor Framework: Deadline for Businesses to Register for New Northern Ireland Retail Movement Scheme Approaches

By Nicola Smith and Francesca Puttock on Posted in Brexit, Environmental, Food Safety, Health & Safety, Product Safety
From October 2023, a broad range of products moving from Great Britain (GB) to Northern Ireland (NI) (and that are intended for “final consumption” in NI) will be processed through a “green lane” and be subject to fewer checks and controls. While this will ultimately facilitate movements of various products, there are implications for businesses … Continue Reading

Deposit return scheme: Circularity Scotland hails “milestone” producer registration and reaffirms August 2023 launch date amid growing scepticism

By Nicola Smith and Francesca Puttock on Posted in Alcohol, Food and Entertainment Licensing, Climate Change & Sustainability, Environmental, Food Safety, Product Safety, Uncategorized
With a planned launch date of 16 August 2023, the pressure is on for the Scottish government to deliver the deposit return scheme (“DRS”) for drinks containers. Despite increased scrutiny of industry readiness, Circularity Scotland (“CSL”) reaffirmed on 2 March that the scheme is on track and that producers responsible for more than 95% of … Continue Reading

Key Federal PFAS Regulatory Developments in 2022 and 2023

By Charli Davis on Posted in Chemicals & Products, Rulemaking & Policy Development
In 2022, US EPA indicated that it would take a more aggressive stance on per- and polyfluoroalkyl substances (PFAS). US EPA developed a PFAS Strategic Roadmap for 2021-2024 that sets timelines by which US EPA plans to take specific actions and sets out its three main directives: 1) research PFAS exposure; 2) restrict PFAS from … Continue Reading

New Plastics Bill Would Require US EPA Action Under TSCA

By Nicole Bothwell on Posted in Chemicals & Products, Climate Change & Sustainability
As interest in regulating the production and use of plastics continues to grow, users of chemicals related to plastics should take note of the newly proposed “Protecting Communities from Plastics Act,” introduced in Congress on December 1, 2022 (the Act).  The Act is intended to identify potential health effects of certain plastics, limit their production, and … Continue Reading

China Publishes Draft List of Key New Pollutants under Pollutant Control Action Plan

By Danelle Gagliardi on Posted in Chemicals & Products, Rulemaking & Policy Development
We have been monitoring the progress China’s Ministry of Ecology and Environment (MEE) has been making on the goals set in its New Pollutant Control Action Plan, released in May 2022. One of the goals of the Plan was to release a list of key “new pollutants” for regulation and control, the categories of which … Continue Reading

2022 Chemicals Workshop Webinar Series: PFAS, REACH and Other Chemical Regulatory Issues

By Squire Patton Boggs on Posted in CERCLA/RCRA, Chemicals & Products, Rulemaking & Policy Development
A recording of PFAS, REACH and Other Chemical Regulatory Issues the second webinar in our two-part 2022 Chemicals Workshop webinar series, in partnership with the Ohio Chemistry Technology Council (OCTC), is now available. In this session, we provided an overview of the rapidly evolving landscape related to per- and polyfluoroalkyl substances (PFAS), including the proposed … Continue Reading

US EPA Launches Initiative to Streamline the Review Process for Certain Electric Vehicle and Clean Energy Chemicals

By ScheLeese Goudy on Posted in Chemicals & Products, Climate Change & Sustainability, Energy & Utilities, Environmental, Mining & Natural Resources
On October 5, 2022, the U.S. Environmental Protection Agency (EPA) announced its intent to streamline the review process of mixed metal oxides (MMOs).  MMOs are a key component in lithium-ion batteries, which are used in electric vehicles and other clean energy initiatives, including in semi-conductors, and renewable energy generation and storage, such as in solar … Continue Reading

Prop 65 Regulatory Update for the Cannabis Industry: Tailored Warnings Become Effective October 1, 2022 with a 1-Year Grace Period for Compliance

By Danelle Gagliardi on Posted in Chemicals & Products
As we noted in a prior post, the California Office of Environmental Health Hazard Assessment (OEHHA) proposed tailored Prop 65 safe harbor warnings for THC and marijuana smoke, following listing THC for reproductive harm and marijuana smoke as cancer-causing in January 2020 (marijuana smoke was already listed for reproductive harm as of 2009). After considerable … Continue Reading

US EPA Resurrects Long-Dormant DINP Rulemaking

By Squire Patton Boggs on Posted in Administrative Procedures Act, Chemicals & Products, Environmental, Rulemaking & Policy Development
While rulemakings under the Administrative Procedure Act typically take several years from proposal to enactment, that can vary significantly.  While some rules run a fairly standard course, others languish for years with no action nor any apparent reason for inaction.  EPA’s recent revival of a proposed rule that is now, were it a person, old … Continue Reading

US EPA’S Draft Screening Level Approach May Broaden Scope of Chemical Risk Evaluations Under TSCA

By Nicole Bothwell on Posted in Chemicals & Products
The United States Environmental Protection Agency (US EPA) continues to advance various aspects of its chemicals regulatory agenda under the Toxic Substances Control Act (TSCA). A key part of the Biden Administration’s revisions to the TSCA program is its planned new screening approach for assessing ambient air and water exposures to fenceline communities. This screening … Continue Reading

China’s New Pollutant Control Action Plan: A Focused Plan that Could Impact the Chemical Industry Outside of China

By Danelle Gagliardi on Posted in Chemicals & Products, Environmental Protection
It is no secret that China has long struggled with implementing measures for pollution control and regulating hazardous chemicals. We have watched this issue closely and published about it in years past here. However, on May 24, 2022, the China State Council issued its most focused plan yet, known as the “New Pollutant Control Action … Continue Reading
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