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Download a PDF of the Forecast 2026. Bergeson & Campbell, P.C. (B&C®), its global consulting affiliate The Acta Group (Acta®), and consortia management affiliate B&C® Consortia Management, L.L.C. (BCCM) are pleased to share with you our Forecast 2026. Our distinguished global team of chemical experts worked hard to summarize our collective best guess on what to expect in the New Year regarding global industrial, agricultural, and biocidal chemical regulatory and policy...
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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...
December 22, 2025
ECHA’s Committees Continue to Evaluate PFAS Uses; ECHA Publishes Guidance for Upcoming Consultation on SEAC’s Draft Opinion
The European Chemicals Agency’s (ECHA) Committees for Risk Assessment (RAC) and for Socio-Economic Analysis (SEAC) met in December 2025. According to ECHA’s December 17, 2025, press release, RAC and SEAC progressed their evaluation of the updated proposal to restrict per- and polyfluoroalkyl substances (PFAS) under the European Union’s (EU) Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation. According to ECHA, both committees reached provisional...
November 13, 2025
EPA Proposes to Narrow Scope of TSCA Section 8(a)(7) PFAS Reporting Rule; Exemptions Would Include De Minimis Amounts, Imported Articles
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...
On October 14, 2025, the Australia Industrial Chemicals Introduction Scheme (AICIS) announced that it has initiated an evaluation on the introduction and use of per- and polyfluoroalkyl substances (PFAS) in Australia under Section 74 of the Industrial Chemicals Act 2019 (IC Act). According to AICIS, the evaluation will review the 522 PFAS listed on the Australian Inventory of Industrial Chemicals. The evaluation will confirm whether the listed PFAS have been introduced in Australia, and if so,...
October 22, 2025
PFAS in Consumer Products: Navigating Multi-State Compliance and Regulatory Strategy, April 14, 2026, 11:00 a.m. – 12:00 p.m. (EST), via webinar
Acta and B&C are pleased to present “PFAS in Consumer Products: Navigating Multi-State Compliance and Regulatory Strategy,” a Lexology Masterclass focused on analyzing the reporting frameworks at the federal and state level, as well as state notification, restriction, and prohibition requirements. In comparing these frameworks and requirements, webinar participants will: Appreciate the complexity of PFAS and the diversity of regulatory approaches; Understand jurisdictional divergence in...
The European Chemicals Agency (ECHA) announced on August 20, 2025, that it published an updated proposal to restrict per- and polyfluoroalkyl substances (PFAS) under the European Union’s (EU) Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation. The authorities from Denmark, Germany, the Netherlands, Norway, and Sweden (Dossier Submitters) submitted the initial proposal in January 2023 and have now completed their evaluation of more than 5,600 scientific and...
On August 15, 2025, Illinois Governor JB Pritzker (D) signed a bill (HB 2516) amending the PFAS Reduction Act to ban certain consumer products containing intentionally added per- and polyfluoroalkyl substances (PFAS). As of January 1, 2032, intentionally added PFAS are banned in cosmetics, dental floss, juvenile products, menstrual products, and intimate apparel. The Act defines PFAS as “a class of fluorinated organic chemicals containing at least one fully fluorinated carbon...
As reported in our April 11, 2025, blog item, applications for currently unavoidable use determinations for products containing intentionally added perfluoroalkyl and polyfluoroalkyl substances (PFAS) and scheduled to be prohibited in Maine on January 1, 2026, were due June 1, 2025. The agenda for the July 17, 2025, meeting of the Maine Board of Environmental Protection (MBEP) includes a proposed amendment to Chapter 90: Products Containing PFAS. According to...
July 14, 2025
Lynn L. Bergeson, “Good News: PFAS Reporting Deadline Postponed,” Chemical Processing, July 14, 2025.
The Minnesota Pollution Control Agency (MPCA) announced recently that it will postpone the Jan. 1, 2026, reporting deadline on products containing intentionally added per- and polyfluoroalkyl substances (PFAS). This is welcome news for businesses that were frantically preparing for the fast-approaching deadline. This column explains the state’s PFAS reporting rule, and summarizes the current, fluid state of play in this state’s evolving PFAS program....