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The European Chemicals Agency (ECHA) announced on September 27, 2023, that it carried out two campaigns during 2021-2023 to remind companies of their obligation to keep their Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) registrations up to date. According to ECHA, 57 of the 689 screened registrations, from 50 companies in 11 European Union (EU) member states, are still in breach of the update requirements under REACH Article 22. ECHA states that it reported these...

Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are pleased to announce that Catherine M. Croke, DBA, Director of Product Stewardship and Regulatory Affairs, has been elected to serve on the Product Stewardship Society’s (PSS) Board of Directors for the 2023 – 2026 term. PSS President Lisa Marie Nespoli, CPPS, said of the newly elected directors: “These accomplished figures have earned recognition as leaders in product stewardship, and we are eager to tap into their...

On September 28, 2023, the U.S. Environmental Protection Agency (EPA) released a long-overdue final rule under Section 8(a)(7) of the Toxic Substances Control Act (TSCA) regarding reporting and recordkeeping requirements for per- and polyfluoroalkyl substances (PFAS). As discussed below, the final rule is not what many of us expected, nor wanted. EPA states that the reporting rule is a statutory requirement under the fiscal year (FY) 2020 National Defense Authorization Act (NDAA) that requires...

The U.S. Consumer Product Safety Commission (CPSC) published a request for information (RFI) on per- and polyfluoroalkyl substances (PFAS) used in commerce or potentially used in consumer products, potential exposures associated with the use of PFAS in consumer products, and potential human health effects associated with exposures to PFAS from their use in consumer products. 88 Fed. Reg. 64890. CPSC also announced the availability of a contractor report with a focus on PFAS that are potentially...

AUSTRALIA AICIS Extends Temporary Recordkeeping Provisions For NICNAS Introducers To April 1, 2024: On September 13, 2023, the Australian Industrial Chemicals Introduction Scheme (AICIS) announced that recordkeeping provisions for introducers that transitioned from the National Industrial Chemicals Notification and Assessment Scheme (NICNAS) to AICIS will continue to be available until April 1, 2024. AICIS notes that these arrangements...

On August 3, 2023, the Joint Subcommittee on Environment, Innovation, and Public Health Sustainable Chemistry Strategy Team (Sustainable Chemistry ST) of the National Science and Technology Council (NSTC) published a report entitled Sustainable Chemistry Report: Framing the Federal Landscape. As reported in our January 19, 2021, memorandum, the fiscal year (FY) 2021 National Defense Authorization Act (NDAA) included the text of the bipartisan Sustainable Chemistry Research and...

The U.S. Environmental Protection Agency (EPA) announced on August 15, 2023, that it issued the third Toxic Substances Control Act (TSCA) test order requiring testing on per- and polyfluoroalkyl substances (PFAS) under EPA’s National PFAS Testing Strategy. EPA has ordered the Chemours Company FC LLC, E. I. du Pont de Nemours and Company, and 3M Company to conduct and submit testing on 2,3,3,3-Tetrafluoro-2-(heptafluoropropoxy)propanoyl fluoride (HFPO-DAF), “a substance used as...

The International Bar Association (IBA) Agriculture and Food Section (AFS), Chaired by Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), is pleased to share a recording from the Capacity Development Webinar for Lawyers on Responsible Land-Based Investments in Agriculture: Latin America Focus. This webinar explores the current regulatory framework for sustainable and responsible investment in agriculture, and panelists discuss how lawyers in the private and public...