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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...

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...

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...

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,...

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...

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....

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...

On May 22, 2025, the Minnesota Pollution Control Agency (MPCA) held a public hearing on its “Proposed Permanent Rules Relating to PFAS in Products; Reporting and Fees” (proposed rule). Administrative Law Judge (ALJ) Jim Mortenson facilitated the hearing, which had more than 100 participants in attendance. MPCA has made available online the PowerPoint document used for the hearing presentation, the hearing exhibits, and a transcript of the hearing. Procedural Background The...

On April 28, 2025, the U.S. Environmental Protection Agency (EPA) outlined upcoming agency action to address per- and polyfluoroalkyl substances (PFAS). According to EPA’s much anticipated announcement, “[i]n line with Administrator Zeldin’s Powering the Great American Comeback initiative, EPA’s work in this space will advance Pillar 1: Clean Air, Land, and Water for Every American, and Pillar 3: Permitting Reform, Cooperative Federalism, and Cross-Agency Partnership.” ...

The U.S. Environmental Protection Agency announced on May 12, 2025, an interim final rule that would extend the dates of the reporting period for data submitted on the manufacture of perfluoroalkyl or polyfluoroalkyl substances (PFAS) under the Toxic Substances Control Act (TSCA). Under the interim final rule, the data submission period would begin April 13, 2026, and end October 13, 2026. Small manufacturers reporting exclusively as article importers would have...

On April 28, 2025, the U.S. Environmental Protection Agency (EPA) outlined upcoming Agency action to address per- and polyfluoroalkyl substances (PFAS). According to EPA’s announcement, “[i]n line with Administrator Zeldin’s Powering the Great American Comeback initiative, EPA’s work in this space will advance Pillar 1: Clean Air, Land, and Water for Every American, and Pillar 3: Permitting Reform, Cooperative Federalism, and Cross-Agency Partnership.” EPA states that these actions...

Register now to join The Acta Group (Acta®) and EPPA for “PFAS Updates: What’s Happening in the U.S. and EU,” a complimentary webinar offering expert updates on per- and polyfluoroalkyl substances (PFAS) regulatory developments. These substances are attracting global legal, regulatory, commercial, and litigation attention as no other “emerging contaminant” has. While the U.S. Administration is new, PFAS regulation continues at a rapid pace and U.S. state initiatives are evolving...

With the January 1, 2026, reporting deadline fast approaching for reporting on products containing intentionally added per- and polyfluoroalkyl substances (PFAS), on April 21, 2025, the Minnesota Pollution Control Agency (MPCA) published a proposed rule intended to clarify the reporting requirements, specify how and what to report, and establish fees. Written comments on the proposed rule are due May 21, 2025, at 4:30 p.m. (CDT). On May 22, 2025, at 2:00...

On April 8, 2025, New Mexico Governor Michelle Lujan Grisham (D) signed the Per- and Poly-Fluoroalkyl Substances (PFAS) Protection Act (HB 212). Like Minnesota and Maine, New Mexico will begin phasing out certain consumer products containing intentionally added PFAS, defining PFAS as “a substance in a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom.” In 2032, New Mexico will prohibit products containing intentionally added PFAS...

On January 21, 2025, the U.S. Environmental Protection Agency’s (EPA) proposed rule seeking to set effluent limitation guidelines for certain per- and polyfluoroalkyl substances (PFAS) under the Clean Water Act (CWA) was withdrawn from Office of Management & Budget (OMB) review following President Trump’s Executive Order implementing a regulatory freeze. Federal action may be halted, but states are beginning to enact legislation that seeks to address PFAS contained in industrial...

On March 5, 2025, Environment and Climate Change Canada (ECCC) announced the availability of its final State of Per- and Polyfluoroalkyl Substances (PFAS) Report (State of PFAS Report) and proposed risk management approach for PFAS, excluding fluoropolymers. The State of PFAS Report concludes that the class of PFAS, excluding fluoropolymers, is harmful to human health and the environment. To address these risks, on March 8, 2025, Canada published a proposed order that would add the...