All Knowledge & Insights By Date

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...

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...

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...

The U.S. Environmental Protection Agency (EPA) issued a final rule on July 28, 2026, extending certain compliance dates applicable to certain entities subject to the risk management rules for perchloroethylene (PCE) and carbon tetrachloride (CTC) under the Toxic Substances Control Act (TSCA). 91 Fed. Reg. 47145. EPA states that it is extending certain Workplace Chemical Protection Program (WCPP) compliance dates for non-federal owners and operators to match the existing compliance dates for...

The U.S. Environmental Protection Agency (EPA) announced on March 24, 2026, that it will propose to extend certain compliance dates in the December 2024 final risk management rules for perchloroethylene (PCE) and carbon tetrachloride (CTC) under the Toxic Substances Control Act (TSCA). According to EPA, it continues to revise the final rules “to ensure they are practical and implementable to protect human health and the environment and maintain uses that power the U.S. economy.” Until EPA...

On June 25, 2025, Bergeson & Campbell, P.C. (B&C®), the Environmental Law Institute (ELI), and the George Washington University (GWU) Milken Institute School of Public Health presented “TSCA Reform -- Nine Years Later.” This virtual conference marked the ninth Toxic Substances Control Act (TSCA) Annual Conference, reflecting on the accomplishments and challenges since the implementation of the 2016 Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg Act) and...

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...

On January 14, 2025, the U.S. Environmental Protection Agency (EPA) issued a proposed rule to address the unreasonable risk of injury to human health presented by Color Index (C.I.) Pigment Violet 29 (PV29) under its conditions of use (COU) as documented in EPA’s January 2021 risk evaluation and September 2022 revised risk determination. 90 Fed. Reg. 3107. The proposed rule states that the Toxic Substances Control Act (TSCA) requires that EPA address by rule any unreasonable risk of injury to...

The U.S. Environmental Protection Agency (EPA) released final risk management rules under the Toxic Substances Control Act (TSCA) for trichloroethylene (TCE) and perchloroethylene (PCE) on December 9, 2024, and for carbon tetrachloride (CTC) on December 11, 2024. EPA states that all uses of TCE will be banned over time, with “the vast majority of identified risks eliminated within one year,” and safer alternatives readily available for the majority of uses. The PCE rule will ban manufacture,...

The U.S. Environmental Protection Agency (EPA) issued a proposed rule on August 8, 2024, to address the unreasonable risk of injury to human health presented by 1-bromopropane (1-BP) under its conditions of use (COU) as documented in EPA’s August 2020 Risk Evaluation for 1-BP and the December 2022 Revised Risk Determination for 1-BP prepared under the Toxic Substances Control Act (TSCA). 89 Fed. Reg. 65066. To address the identified unreasonable risk, EPA proposes requirements to, among other...