On May 18, 2026, the U.S. Environmental Protection Agency (EPA) announced two proposed rules. The first proposed rule would uphold the federal drinking water Maximum Contaminant Levels (MCL) for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) while providing an option for drinking water systems to request two additional years to comply with the enforceable limits. The second proposed rule would rescind the regulatory determinations and regulations for perfluorohexane...
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The Strengthening Environmental Protection for a Healthier Canada Act (the Act), enacted in 2023 to modernize the Canadian Environmental Protection Act, 1999 (CEPA), requires the creation of a “Watch List” of substances capable of becoming toxic to inform Canadians and businesses of substances that they may wish to avoid. On April 28, 2026, Environment and Climate Change Canada (ECCC) announced the publication of the Watch List Approach (the Approach) in the CEPA Registry. The Approach...
The Chair of the New Mexico Environmental Improvement Board (NMEIB) signed a Final Order and Statement of Reasons on April 17, 2026, regarding the adoption of a rule on per- and polyfluoroalkyl substances (PFAS) in consumer products. The final rule, scheduled to be published in New Mexico’s Register on May 5, 2026, with the Final Order and Statement of Reasons, includes prohibitions for certain consumer products in 2027 and 2028;...
The European Chemicals Agency (ECHA) will hold a webinar on May 7, 2026, from 11:00-12:40 (Helsinki time) on the restriction proposal on per- and polyfluoroalkyl substances (PFAS). ECHA experts will present the Risk Assessment Committee’s (RAC) final opinion and the Socio-Economic Analysis Committee’s (SEAC) draft opinion, covering hazards, emissions, risks, alternatives, socio-economic impacts, and next steps. The session includes a one-hour live question and answer...
On April 6, 2026, the U.S. Environmental Protection Agency (EPA) released the draft of its sixth Contaminant Candidate List (CCL) issued under the Safe Drinking Water Act (SDWA), including for the first time microplastics as a priority contaminant group. 91 Fed. Reg. 17186. Section 1412(b)(1)(B)(i) of SDWA, as amended in 1996, requires that EPA publish the CCL every five years. The contaminants on the List are not regulated under national primary drinking water regulations, but either occur or...
March 31, 2026
RAC and Draft SEAC Opinions Support REACH PFAS Restriction with Targeted Derogations; Comments on Draft SEAC Opinion Due May 25
On March 26, 2026, the European Chemicals Agency (ECHA) released the final opinion of its Risk Assessment Committee (RAC) and the draft opinion of its Socio-Economic Analysis Committee (SEAC) on the 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, RAC and SEAC “support an EU-wide restriction, subject to specific derogations, on the...
The Minnesota Pollution Control Agency (MPCA) held a webinar on February 26, 2026, on its currently unavoidable use (CUU) rule concepts. Under Minnesota’s per- and polyfluoroalkyl substances (PFAS) statute, beginning January 1, 2032, intentionally added PFAS in almost all products will be prohibited in Minnesota unless MPCA issues a CUU determination for the use of the PFAS. MPCA has posted a recording of the webinar, presentation slides, and a summary of the draft rule...
March 4, 2026
RAC Adopts Opinion on Proposed REACH Restriction Proposal for PFAS, ECHA Will Publish Opinion “Soon”
The European Chemicals Agency (ECHA) announced on March 3, 2026, that its Risk Assessment Committee (RAC) has concluded its evaluation of the proposal to restrict per- and polyfluoroalkyl substances (PFAS) under the European Union’s (EU) Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation. ECHA notes that RAC drew on “an extensive and independent evaluation of PFAS hazards, volumes, emissions, risks and the likely effectiveness of a restriction as well as...
The United Kingdom’s (UK) Health and Safety Executive (HSE) announced on February 3, 2026, that the Department for Environment, Food and Rural Affairs (Defra) has published a PFAS Plan, a “cross-government, science-led” plan to understand the impacts of per- and polyfluoroalkyl substances (PFAS) on public health and the environment, with coordinated actions to minimize risks. Defra notes that there is no universally agreed definition of PFAS, but states that the Organisation for Economic...
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...
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: a multi-state compliance guide,” 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: a multi-state compliance guide,” 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 PFAS regulation to better...
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....
July 1, 2025
EP Research Service Publishes Think Tank Briefing on EU Chemicals Strategy for Sustainability
On June 23, 2025, the European Parliamentary Research Service (EPRS) published a Think Tank briefing entitled “Targeted scrutiny of the EU chemicals strategy for sustainability.” According to EPRS, while the European Commission (EC) has made progress in implementing initiatives outlined in the 2020 Chemicals Strategy for Sustainability, certain key actions remain unfulfilled. These include revising the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation...