PFAS

Yesterday, the European Parliament approved a new (recast) Urban Wastewater Treatment Directive (“UWWTD”) that will impose new additional costs on producers marketing pharmaceutical and cosmetic products in the European Economic Area by the end of 2027.  Some studies suggest that the costs that producers would have to collectively pay could be around €1 billion per Member State.  This is well above the figures published in the Commission’s impact assessment, which estimated the annual cost of implementing the various requirements of the UWWTD in all Member States at €3.8 billion, including €1.2 billion for micro-pollutants treatment.

The upcoming UWWTD lays down rules on the collection, treatment, and discharge of urban wastewater, and puts particular emphasis on the implementation of the polluter pays principle.  The Directive aims to address the environmental and health concerns resulting from the presence of micro-pollutants, other pollutants (e.g., heavy metals, PFAS), microplastics and antimicrobial resistant (“AMR”) bacteria in European waters.  It introduces new measures for the treatment of wastewater, including quaternary treatment for micro-pollutants, and makes producers of pharmaceutical and cosmetic producers pay for such treatment.Continue Reading New EU Wastewater Treatment Fees on Producers of Pharmaceutical and Cosmetic Products

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 PFASContinue Reading Key Takeaways from EPA’s EPCRA PFAS Rule

            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