On May 12, 2025, the U.S. Environmental Protection Agency (EPA) announced an amendment delaying the data submission period for the Toxic Substances Control Act (TSCA) PFAS reporting rule, which will now begin on April 13, 2026, and end on October 13, 2026. Small manufacturers who report solely as article importers will have until April 13
Administrators May Change, But PFAS Is Forever: EPA Announces PFAS Plan
The U.S. Environmental Protection Agency (EPA), under Administrator Lee Zeldin, has unveiled its anticipated strategy for addressing the pervasive issue of per- and polyfluoroalkyl substances (PFAS), often referred to as “forever chemicals.” While the announcement provides a broad framework, specific details (particularly regarding potential changes to previous rulemakings under CERCLA and the Safe Drinking Water
It’s Official, the Transfer Act will be “Sunset”
For the last 40 years, the Connecticut Transfer Act has primarily driven the remediation of contaminated property in Connecticut—this will change early next year.
Currently, the Connecticut Transfer Act (Conn. Gen. Stat. § 22a-134 et seq.) requires site-wide investigation, and potential remediation, upon the “transfer” of an “establishment” as defined by the Transfer Act.
PFAS Reporting Rules to Ring in the New Year
As we have previously reported, PFAS (per- and polyfluoroalkyl substances) are a class of substances coming under increasing regulatory scrutiny. As manufacturers ring in the new year they should be aware of two new PFAS reporting requirements that could need careful attention in 2024.
De Minimis Exemption No Longer Available for PFAS Under EPCRA
EPA Proposes Enforceable Drinking Water Standards For PFAS
Last week EPA released its proposal for the first set of Maximum Contaminant Levels (MCLs) under the Clean Water Act for per- and polyfluoroalkyl substances (PFAS). In contrast to non-enforceable health advisory levels introduced in 2016 and revised in 2022, MCLs constitute enforceable drinking water standards that will impact drinking water utilities and industry nationwide.
EPA Proposes to Designate PFOS and PFOA as CERCLA Hazardous Substances
Last week, the U.S. Environmental Protection Agency (EPA) released a pre-publication version of a Proposed Rule to designate PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund). This marks the next step in a trend of increasing regulation of per- and polyfluoroalkyl substances (PFAS), a class
Changes to PCB Remediation Expected Under Proposed Rule
On October 22, 2021, EPA published a proposed rule that would, if adopted, provide a significantly enhanced additional pathway for remediation of sites impacted by polychlorinated biphenyls or PCBs. EPA helpfully included a redline version showing proposed changes to the regulatory text. EPA is receiving comments on the proposed rule until December 21, 2021.
PCBs