All Knowledge & Insights By Date

Perfluoroalkyl and polyfluoroalkyl substances (PFAS) are attracting global legal, regulatory, commercial, and litigation attention as no other “emerging contaminant” has. Companies producing, processing, distributing, and/or using these substances must be aware of global legal and scientific developments and take steps now to minimize legal, regulatory, and commercial risk. Bergeson & Campbell, P.C. (B&C®) and its global consulting affiliate The Acta Group (Acta®) have prepared...

On December 3, 2025, the U.S. Environmental Protection Agency (EPA) announced the availability of and solicited public comment on an Updated Draft Risk Calculation Memorandum (Draft Memorandum) to inform a revised draft risk evaluation for formaldehyde under the Toxic Substances Control Act (TSCA). 90 Fed. Reg. 55726. EPA states that after further consideration of comments raised during the scientific peer review process, it is reconsidering the use of certain hazard values in the formaldehyde...

The European Union Deforestation Regulation (EUDR) appears to be headed for yet another full-year delay following growing political pressure, concerns about the readiness of the European Commission’s (EC) information technology (IT) systems, and intensifying industry warnings that the current December 30, 2025, compliance deadline is becoming increasingly unrealistic. While the EC has not yet officially postponed the implementation date, the signals coming out of Brussels are...

On Thanksgiving Eve, November 26, 2025, the White House Office of Science and Technology Policy (OSTP) requested input from interested parties on federal policy updates “that aim to accelerate the American scientific enterprise, enable groundbreaking discoveries, and ensure that scientific progress and technological innovation benefit all Americans.” 90 Fed. Reg. 54412. OSTP states that “[t]hrough this Request for Information (RFI), OSTP seeks input from academia; private sector...

On November 24, 2025, the U.S. Environmental Protection Agency (EPA) released the key default values that it uses in its risk assessments of new chemicals under the Toxic Substances Control Act (TSCA). EPA is making the assumptions available on its website in the New Chemicals Division Reference Library. EPA states that it expects the publication of the default values “to improve efficiency, reducing the likelihood that submissions need to be reworked or resubmitted.” According to EPA,...

On November 19, 2025, the U.S. Environmental Protection Agency (EPA) announced the availability of and requested comment on a draft risk evaluation under the Toxic Substances Control Act (TSCA) for 1,2-dichloroethane (Chemical Abstracts Service Registry Number® (CAS RN®) 107-06-2, also known as ethylene dichloride or EDC). 90 Fed. Reg. 52054. EPA notes that the purpose of risk evaluations under TSCA is to determine whether a chemical substance presents an unreasonable risk of injury to health...

The state of Oregon’s packaging and paper Extended Producer Responsibility (EPR) program, enacted in 2021, has progressed into its enforcement stage. With the first fee obligations and real-world compliance deadlines now in place, the risk of litigation under and against the program has transitioned from theoretical to real. In July 2025, a major trade association, National Association of Wholesaler-Distributors (NAW), filed a constitutional challenge to Oregon’s law, raising issues that are...

On November 13, 2025, the U.S. Environmental Protection Agency (EPA) issued a proposed rule to amend the Toxic Substances Control Act (TSCA) Section 8(a)(7) regulation for reporting and recordkeeping requirements for perfluoroalkyl and polyfluoroalkyl substances (PFAS). 90 Fed. Reg. 50923. As reported in our October 3, 2023, memorandum, the final rule requires manufacturers (including importers) of PFAS and PFAS-containing articles in any year since 2011 through 2022 to report information...