On November 10, 2025, EPA released a proposed rule under the Toxic Substances Control Act (“TSCA”), proposing to amend its reporting requirements relating to per- and polyfluoroalkyl substances (“PFAS”). The original rule, promulgated in 2023, led to concerns by some regulated entities that it would be difficult to collect the
Continue Reading EPA Proposes Changes to TSCA PFAS Reporting RulePFAS
EPA Finalizes Rule Listing PFOA and PFOS as CERCLA Hazardous Substances
By Thomas Brugato on
Posted in PFAS
On April 17, 2024, the EPA released a final rule designating two perfluorinated chemicals—Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS)—as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). EPA also released enforcement guidance explaining how it intends to apply the new listing with respect to certain types of potentially responsible parties.Continue Reading EPA Finalizes Rule Listing PFOA and PFOS as CERCLA Hazardous Substances
Key Takeaways from EPA’s EPCRA PFAS Rule
By Thomas Brugato on
Posted in Chemicals, Pesticides, & Plastics, PFAS
On October 20, 2023, EPA released a final rule under the Emergency Planning and Community Right to Know Act (“EPCRA”) relating to per- and polyfluoroalkyl substances (“PFAS”). The Rule makes important revisions to EPA’s Toxic Release Inventory (“TRI”) program relating to 189 specified PFAS. Continue Reading Key Takeaways from EPA’s EPCRA PFAS Rule
Key Takeaways from EPA’s PFAS Reporting Rule
By Thomas Brugato on
Posted in PFAS
On September 28, 2023, EPA released a final rule under the Toxic Substances Control Act (“TCSA”) mandating reporting relating to past manufacturing of per- and polyfluoroalkyl substances (“PFAS”). Below are key takeaways companies that may be subject to these reporting requirements should keep in mind.Continue Reading Key Takeaways from EPA’s PFAS Reporting Rule