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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...

Effective 1 January 2027, distributors will be explicitly identified as duty holders under Article 45 of the Classification, Labelling and Packaging (CLP) Regulation. This clarification is intended to provide greater clarity regarding distributors’ responsibilities in supporting Poison Centre Notifications (PCN) requirements and to help address information gaps across the supply chain. The clarification is particularly relevant to companies that: Sell mixtures in a member...

On September 15, 2026, the U.S. Court of Appeals for the Fifth Circuit granted Industry Petitioners’ petition for review of the U.S. Environmental Protection Agency’s (EPA) 2024 risk management rule for methylene chloride (MC). East Fork Enterprises v. EPA (No. 24-60227, consolidated with No. 24-60256). The court states that “[f]inding that errors of law occurred and substantial evidence did not support EPA’s decision,” it grants the Industry Petitioners’ petition for...

This memorandum is the first in a two-part series providing an overview of the consortia that are managed by B&C® Consortia Management, L.L.C. (BCCM). Many are aware of Bergeson & Campbell, P.C.’s (B&C®), The Acta Group’s (Acta®), and BCCM’s deep expertise and extensive practice on matters related to the Toxic Substances Control Act (TSCA) and support for consortia clients working on issues related to TSCA. Importantly also, BCCM has extensive experience in other chemical...

The European Chemicals Agency (ECHA) will hold two webinars on September 23, 2026, and November 5, 2026, aimed at assisting micro, small, and medium-sized enterprises (SME) with meeting chemical regulatory obligations. September 23, 2026, from 11:00-13:00 (Helsinki time), SME webinar: Steps for notifying to poison centres; and November 5, 2026, from 11:00-13:00 (Helsinki time), Applying for reduced fees: what SMEs need to do....

On August 27, 2026, Judge Michael H. Simon issued a Findings of Fact and Conclusions of Law in the case of National Association of Wholesaler-Distributors v. Feldon, finding that Oregon's Plastic Pollution and Recycling Modernization Act (RMA) does not violate the Dormant Commerce Clause or the Due Process Clause. Following a five-day bench trial before the U.S. District Court for the District of Oregon in July 2026, Plaintiff National Association of Wholesaler-Distributors (NAW) and...

The European Unions (EU) new hazard classes are approaching the end of their transitional period for substances placed on the EU market and in the supply chain before 1 May 2025. Introduced by the EU Commission Delegated Regulation (EU) 2023/707, the new hazard classes cover the following properties: Endocrine disruption (ED) for human health and the environment; Persistent, bioaccumulative, and toxic (PBT); Very persistent, very bioaccumulative (vPvB); Persistent, mobile, and toxic (PMT); and...

On August 19, 2026, the U.S. Environmental Protection Agency (EPA) announced the availability of and requested public comment on the draft risk evaluation under the Toxic Substances Control Act (TSCA) for ethylene dibromide. 91 Fed. Reg. 53618. EPA states that the purpose of risk evaluations under TSCA is to determine whether a chemical substance presents an unreasonable risk of injury to health or the environment under the conditions of use (COU), including unreasonable risk to potentially...

On September 2, 2026, U.S. Customs and Border Protection (CBP) published an important and consequential advance notice of proposed rulemaking (ANPRM) stating that it “is considering amending its regulations to give CBP greater visibility into the supply chains of goods imported into the United States.” 91 Fed. Reg. 56408. CBP seeks comments on new requirements that it claims will enhance visibility into the parties involved in the importation of goods, integrate innovative technical...

Ticks have long been an unwelcome consequence of spending time outdoors, but the public health significance of tick exposure is becoming difficult to ignore. Changes in the geographic distribution of tick species, longer periods of seasonal activity in some regions, changing land-use patterns, movement of wildlife hosts, and increased human exposure to tick habitats make the risk of tick-borne disease an increasingly important public health issue in the United States and elsewhere. In the United...

Following the April 27, 2026, European Parliament Environmental Committee announcement that the European Commission (EC) would not proceed with a legislative proposal for a comprehensive revision of the European Union’s (EU) Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation, major reforms -- such as the registration of polymers -- appear to be off the table. Technical amendments to the REACH Annexes through comitology remain possible, however, although it...