ARTICLE
17 September 2025

Monthly Federal Developments Memorandum

BC
Bergeson & Campbell

Contributor

Bergeson & Campbell, P.C. is a Washington D.C. law firm focusing on chemical product approval and regulation, product defense, and associated business issues. The Acta Group, B&C's scientific and regulatory consulting affiliate provides strategic, comprehensive support for global chemical registration, regulation, and sustained compliance. Together, we help companies that make and use chemicals commercialize their products, maintain compliance, and gain competitive advantage as they market their products globally.
Bergeson & Campbell, P.C. (B&C®) and Chemical Watch are pleased to present FIFRA Fundamentals, a two-day course taught by professionals from B&C's renowned Federal Insecticide, Fungicide, and Rodenticide Act...
Worldwide Energy and Natural Resources

FIFRA Fundamentals, September 24-25, 2025, via webinar

Bergeson & Campbell, P.C. (B&C®) and Chemical Watch are pleased to present FIFRA Fundamentals, a two-day course taught by professionals from B&C's renowned Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) team. Lisa R. Burchi, Of Counsel; Heather F. Collins, M.S., Regulatory Consultant; Dana S. Lateulere, Regulatory Consultant; and Meibao Zhuang, Ph.D., Senior Scientist/Regulatory Consultant, will share legal, scientific, and policy knowledge needed to support strategic planning of pesticide-related compliance requirements. Firm clients and friends may contact events@chemicalwatch.com and share code BC-FIFRA15 to receive 15% off the cost of registration.

Bergeson & Campbell, P.C. And LexisNexis Publish 2025 Edition Of Guide to the Toxic Substances Control Act (TSCA)

B&C is pleased to announce publication of the 2025 edition of Guide to the Toxic Substances Control Act (TSCA), LexisNexis (Guide to TSCA). Authored by members of B&C's renowned TSCA practice group, including Lynn L. Bergeson, Heather J. Blankinship, Lisa R. Burchi, Richard E. Engler, Ph.D., Kelly N. Garson, Lara A. Hall, RQAP-GLP, and Carla N. Hutton, the Guide to TSCA is the definitive comprehensive treatise on TSCA, written for lawyers, regulatory affairs specialists, and commercial and business people who need to understand the details of this law. Firm clients and friends may use the code TSCASAVE20 through December 31, 2025, for 20% off the cost of the book when purchasing via the LexisNexis online store.

TSCA/FIFRA/TRI

CEA Withdraws Section 21 Petition Seeking Reconsideration Of 2024 Rule Regarding Procedures For Chemical Risk Evaluation; EPA Intended To Issue NPRM In July 2025

As reported in our May 30, 2025, blog item, on May 15, 2025, the Center for Environmental Accountability (CEA) filed a petition under Section 21 of TSCA requesting that the U.S. Environmental Protection Agency (EPA) reconsider the 2024 final rule regarding procedures for chemical risk evaluation under TSCA and initiate a rulemaking to amend certain provisions in 40 C.F.R. Part 702, subpart B. According to CEA, the current process "has led to overly conservative risk conclusions and, in turn, unnecessary risk management rules that force industry to abandon well-studied chemistries that provide beneficial uses in our daily lives." According to an August 13, 2025, letter from EPA, on August 12, 2025, CEA withdrew its petition and EPA now considers the petition closed. More information is available in our September 5, 2025, blog item.

EPA Releases New Mobile Tool To Help Farmers Implement Recommended Ecological Pesticide Mitigation Measures And Announces Webinar On Mitigation Measures

On August 14, 2025, EPA announced the availability of its Pesticide App for Label Mitigations (PALM), which is described as an "easy-to-use, mobile-friendly tool to serve as a one-stop shop that helps farmers and applicators use EPA's mitigation menu to reduce pesticide exposure to nontarget species from agricultural crop uses." According to EPA, this new tool will allow farmers to access quickly mitigation information from the final Insecticide Strategy, Herbicide Strategy, and other strategies while in the field. To assist the public on how to use the new mobile tool PALM and provide information on mitigation measures for pesticide users, EPA will be holding a public webinar on September 16, 2025. Information on how to register for the webinar is available here. EPA states it encourages users to submit feedback on and suggest future enhancements to PALM. To submit feedback on PALM, please e-mail PALM@epa.gov. For more information on the new mobile tool, please read our August 22, 2025, blog item.

GAO WatchBlog Item Looks At Earlier Report On EPA's New Chemicals Program

The U.S. Government Accountability Office (GAO) announced on August 14, 2025, a WatchBlog item entitled "EPA's New Chemicals Program Could Improve Safety If Better Managed" that examines GAO's January 2025 report on EPA's New Chemicals Program (NCP). In its January 2025 report, GAO reviewed EPA's efforts and interviewed some chemical manufacturers that had submitted notices for new chemicals. While many manufacturers cited strengths in the NCP, GAO states that some manufacturers reported experiencing delays that have impacted their businesses, "including by harming customer relations and hindering their ability to enter the market." GAO notes that a delay "could create a competitive advantage for existing chemicals at the expense of potentially safer new chemicals." GAO's January 2025 report included recommendations for how EPA could address shortcomings in its plan to improve the performance of the NCP. More information on GAO's report is available in our January 23, 2025, blog item.

EPA Extends Postponement Of Effective Date Of Certain Provisions Of Final TCE Risk Management Rule; Will Issue Interim Final Rule On Compliance Date Extensions

On August 20, 2025, EPA extended the postponement of the effectiveness of certain regulatory provisions of the final TSCA risk management rule for trichloroethylene (TCE) to November 17, 2025. 90 Fed. Reg. 40534. EPA is postponing certain requirements most recently postponed in June 2025. EPA notes that these requirements relate only to the TSCA Section 6(g) exemptions in the final TCE rule. EPA states that "[i]n light of the fact that the pending litigation is still ongoing and for the same reasons as set forth in the Initial Notice, EPA has determined that justice requires a 90-day extension of the postponement of the effective date (i.e., until November 17, 2025) of the conditions for each of the TSCA section 6(g) exemptions." More information is available in our August 22, 2025, blog item.

EPA announced on September 12, 2025, that it is issuing an interim final rule for risk management for TCE. The interim final rule keeps the ban in place while extending compliance dates for critical infrastructure and national security applications resulting from the use of TCE as a processing aid in the manufacture of nuclear fuel and for certain processors of industrial chemicals who dispose of TCE to wastewater. According to EPA, these changes are intended to provide impacted businesses with a reasonable transition time timeline to comply with the provisions of the risk management rule. Publication of the interim final rule in the Federal Register will begin a 30-day comment period. EPA notes that the current deadlines remain effective until modified through the rulemaking, but "[e]nforcement of the current deadlines is a low enforcement priority for the agency, and EPA intends to focus its resources on compliance with the new compliance dates that will be established by this rulemaking."

EPA Releases White Paper On Determining The Absence Of Novel Proteins In The Saliva Of Genetically Engineered Mosquitoes For Mosquito Control

EPA announced on August 21, 2025, the availability of and solicited public comment on materials that are being submitted to the FIFRA Scientific Advisory Panel (SAP) for peer review on "Determining the Absence of Novel Proteins in the Saliva of Genetically Engineered Mosquitoes for Mosquito Control." 90 Fed. Reg. 40829. The white paper, charge questions, background documents, and related supporting materials are available for public review and comment. Written comments on the peer review documents (white paper, charge questions, background documents, and related supported materials) are due September 22, 2025. The FIFRA SAP will consider and review the documents at a three-day virtual public meeting November 3-5, 2025. EPA called for public comment on the candidates being considered as ad hoc peer reviewers on August 20, 2025. EPA will post information on its website on how to register for the meeting and provide comments in October 2025. More information is available in our August 25, 2025, blog.

TRI National Analysis For RY 2023 Shows Decrease In Releases

EPA released on August 21, 2025, its Toxics Release Inventory (TRI) National Analysis for reporting year (RY) 2023, which "shows that toxic chemical releases have decreased as the chemical industry's contribution to the national Gross Domestic Product (GDP) has increased." According to EPA, highlights from the analysis include:

  • Between 2014 and 2023, environmental releases of TRI-listed chemicals fell 21 percent, including a 32 percent decrease in air releases. During this ten-year period, releases from manufacturing facilities decreased by 15 percent while the manufacturing sector's contribution to the U.S. GDP increased by 13 percent;
  • A feature profile on automotive manufacturing shows that, from 2014 to 2023, this sector's value to the economy increased by 34 percent while chemical releases decreased by 14 percent;
  • In 2023, facilities managed 90 percent of their TRI chemical waste through preferred practices such as recycling, energy recovery, and treatment;
  • From 1998 to 2023, companies managing TRI chemicals, which include lead, mercury, dioxins, and per- and polyfluoroalkyl substances (PFAS) chemicals, have decreased releases by 54 percent while the national GPD has increased by 74 percent; and
  • For RY 2023, nine PFAS were added to the reporting requirements for a total of 189 PFAS tracked by the TRI program. During 2023, 61 facilities managed 1.6 million pounds of PFAS as waste and decreased chemical releases by 16 percent.

EPA will hold a public webinar on September 30, 2025, at 3:00 p.m. (EDT) to provide an overview of the 2023 TRI National Analysis.

EPA Submits Proposed Rule Revising TSCA Section 8(a)(7) PFAS Rule To OMB For Review

According to the Office of Management and Budget (OMB) website, on August 29, 2025, EPA submitted a proposed rule entitled "Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping under the Toxic Substances Control Act (TSCA); Revision to Regulation" to OMB for review. When EPA postponed the reporting period from July 11, 2025, to April 13, 2026, EPA indicated that it was separately considering reopening certain aspects of the October 2023 rule to public comment. The proposed rule submitted to OMB is not publicly available.

Nominations Of Peer Reviewers For EPA's Risk Evaluation Of D4 Are Due September 25, 2025

EPA announced on September 10, 2025, that it is seeking nominations of scientific and technical experts to be considered as ad hoc reviewers assisting the Science Advisory Committee on Chemicals (SACC) with the peer review of the draft risk evaluation of octamethylcyclotetrasiloxane (D4) under TSCA. EPA states that these nominations will help it select approximately seven to eight ad hoc reviewers to assist SACC with its review. Nominations for ad hoc reviewers should include the candidate's name, affiliation, contact information, and must be submitted by September 25, 2025, to the Office of Chemical Safety and Pollution Prevention (OCSPP) Peer Review mailbox at ocspp-peerreview@epa.gov.

EPA Will Reconsider Final Risk Management Rule For Carbon Tetrachloride

EPA announced on September 12, 2025, its decision to reconsider the 2024 final risk management rule for carbon tetrachloride. According to EPA, after it published the final rule, several legal challenges were filed. These petitions for review were consolidated in the U.S. Court of Appeals for the Eighth Circuit. EPA has requested that the court hold these cases in abeyance while the Agency reconsiders the final rule. EPA sates that during abeyance, it intends to reconsider the final rule through notice-and-comment rulemaking, including but not limited to the use of the Existing Chemical Exposure Limit (ECEL) of 0.03 parts per million (ppm) promulgated as part of the Workplace Chemical Protection Program for carbon tetrachloride, to ensure that the rule is implementable to protect workers consistent with statutory requirements. EPA plans to open a comment period on the final rule as a first step in its efforts to reconsider and, if appropriate, revise the final risk management rule.

TSCA CBI Substantiations Will Begin To Expire In 2026

Under the 2016 Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg Act) amendments to TSCA, most confidential business information (CBI) claims will expire after ten years unless reasserted and substantiated. This means that a CBI claim made in 2016 will expire in 2026 unless the claim is reasserted and resubstantiated before the end of the ten-year period. The beginning of the sunset process will be a challenge and learning experience for submitters and EPA. Submitters should begin now to ensure that their older submissions have up-to-date technical contact(s) and consider adding one or more agents to ensure that EPA will be able to communicate confidently with the contact. Submitters should also monitor the list that EPA posts and watch for updates. More information is available in our September 12, 2025, blog item.

RCRA/CERCLA/CWA/CAA/PHMSA/SDWA

EPA Reviews And Renews Eligibility For Application-Specific HFC Allowances

On August 26, 2025, EPA published a final rule establishing, pursuant to the statutory framework established in the American Innovation and Manufacturing Act of 2020 (AIM Act), the eligibility of six applications to continue to receive priority access to allowances to produce or import hydrofluorocarbons (HFC). 90 Fed. Reg. 41676. The rule establishes the framework for how EPA interprets the statutory criteria for assessing whether to renew the eligibility of applications to receive application-specific allowances and sets out determinations to renew or not renew each of the six applications that currently receive application-specific allowances. EPA is also revising the Technology Transitions regulations relevant to the specific applications under review, a procedural process for submitting a petition to designate a new application as eligible for priority access to allowances, the methodology used to allocate allowances to application-specific allowance holders for calendar years 2026 and beyond, and limited revisions to existing regulations. In addition, EPA is authorizing an entity to produce regulated substances for export. Lastly, EPA is making final certain regulatory confidentiality determinations for newly reported information. The rule will be effective September 25, 2025.

EPA Amends NESHAP For Polyether Polyols Production Industry

On September 2, 2025, EPA amended the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Polyether Polyols Production under the Clean Air Act (CAA). 90 Fed. Reg. 42323. EPA states that "[s]pecifically, for this NESHAP, the EPA is finalizing the removal of affirmative defense provisions associated with the violation of air emission standards due to malfunctions." The final rule was effective September 2, 2025.

EPA Proposes To End GHG Reporting Program

EPA announced on September 12, 2025, a proposed rule to end the Greenhouse Gas (GHG) Reporting Program. EPA states that "[u]nlike other mandatory information collections under the CAA, the [GHG Reporting Program] is not directly related to a potential regulation and has no material impact on improving human health and the environment." If issued in final, the proposed rule would remove reporting obligations for most large facilities, all fuel and industrial gas suppliers, and carbon dioxide injection sites. Publication of the proposed rule in the Federal Register will begin a public comment period.

FDA

FDA Announces Food Allergen Virtual Meeting

On August 18, 2025, the U.S. Food and Drug Administration (FDA) announced a meeting, "FDA Virtual Public Meeting on Food Allergen Thresholds and Their Potential Applications," scheduled for November 18-20, 2025. The three-day public meeting will feature presentations and panel discussions by invited speakers on November 18 followed by listening sessions on November 19-20. FDA will open a docket on November 18 for participants to submit comments. Additional meeting details and registration information will be provided in September 2025.

FDA Updates Substances Under Review

On August 19, 2025, FDA announced an update to the "List of Select Chemicals in the Food Supply Under FDA Review" to provide more insight on the status of its post-market assessment of chemicals in the food supply. This updated list includes select food ingredients (including food additives and color additives), food contact substances, and contaminants under FDA review. The chemicals new to the list are:

  • Butylated hydroxyanisole (BHA) and butylated hydroxytoluene (BHT);
  • Azodicarbonamide (ADA); and
  • FD&C Blue No. 1, FD&C Blue No. 2, FD&C Green No. 3, FD&C Red No. 40, FD&C Yellow No. 5, and FD&C Yellow No. 6.

This post-market review effort is part of a larger initiative to improve food chemical oversight.

FDA Adds Authorized Uses For Hydrogen Peroxide

On September 3, 2025, FDA issued a final amendment order that provides for the safe use of hydrogen peroxide in food as an antimicrobial agent, oxidizing and reducing agent, and bleaching agent, and to remove sulfur dioxide. 90 Fed. Reg. 42535. The amendment was in response to a Food Additive Petition (FAP) filed by Cargill, Inc. The secondary direct food additive regulation for hydrogen peroxide at 21 C.F.R Section 173.356 was updated on September 3, 2025, to include the additional uses. Either electronic or written objections and requests for a hearing on the order must be submitted by 11:59 p.m. Eastern Time on October 3, 2025.

FDA Launches Real-Time Adverse Event Reporting Dashboard For Cosmetic Products

FDA announced on September 12, 2025, the launch of the FDA Adverse Event Reporting System (FAERS) Public Dashboard for Cosmetic Products, an interactive tool designed to facilitate the public's ability to query real-time adverse event data on cosmetic products. According to FDA, "[t]he user-friendly platform allows users to download report listings or data sets, with reports being updated daily to include the most recent submissions." The dashboard is dedicated exclusively to reports of cosmetic product adverse events, including serious adverse event reports submitted by responsible persons for cosmetic products under requirements established by the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), as well as voluntary adverse event reports submitted to FDA by healthcare professionals, consumers, salon professionals, cosmetologists, and others. The FAERS dashboard contains adverse event reports for cosmetic products, such as moisturizers, shampoos, conditioners, hair dyes and tattoos. FDA notes that it has not verified reports in the dashboard and that their publication does not indicate that FDA has concluded the product caused the adverse event. Additionally, the FAERS data are not an indicator of the safety profile of the cosmetic product. Frequently asked questions (FAQ) are available.

NANOTECHNOLOGY

Canada's Plan Of Priorities Includes Several Nanoscale Materials

On July 23, 2025, Environment and Climate Change Canada (ECCC) announced the release of the Plan of Priorities, a multi-year plan that outlines upcoming priorities for the assessment of chemical substances. The Plan includes a list of more than 30 substances and substance groups prioritized for assessment, including nanoscale silver, nanoscale zinc oxide, and nanoscale forms of titanium dioxide (nano-TiO2). More information is available in our August 29, 2025, blog item.

ISO Publishes Standards For Graphene-Related 2D Materials

The International Organization for Standardization (ISO) recently published two standards for graphene-related two-dimensional (2D) materials:

More information is available in our September 8, 2025, blog item.

BIOBASED/RENEWABLE PRODUCTS/SUSTAINABILITY

B&C® Biobased And Sustainable Chemicals Blog

For access to a summary of key legislative, regulatory, and business developments in biobased chemicals, biofuels, and industrial biotechnology, go to https://www.lawbc.com/brand/bioblog/.

PUBLIC POLICY AND REGULATION

Public Policy And Regulation Blog"

Our insights on policy developments affecting industrial and agricultural chemicals and the products in which they are included are available at https://www.lawbc.com/brand/publicpolicyblog/.

LEGISLATIVE

Bipartisan Bill Would Remove PFAS From Drinking Water

On August 14, 2025, Representatives Hillary Scholten (D-MI) and Brian Fitzpatrick (R-PA), members of the bipartisan Congressional PFAS Task Force, introduced the Public Utility Remediation and Enhancement for Water Act (the PURE Water Act) (H.R. 4961). According to Scholten's August 14, 2025, press release, the bill would provide funding for municipal water treatment facilities to help them remove PFAS from drinking water.

MISCELLANEOUS

Microplastics In 2025: Regulatory Trends And Updates

Microplastics are, in recent years, at the forefront of regulatory and policy driven conversations across the United States. Regulatory measures to address microplastics at both state and federal levels have been introduced with increasing frequency. This trend holds true in 2025, which has already seen a significant quantity of legislative, regulatory, and policy proposals and actions in the microplastics sphere. Ongoing interest in microplastics and regulations suggests continued increases in regulatory activity moving forward — although the ways in which the regulations will manifest remain to be seen. For an overview of microplastics regulatory and policy developments from 2025 to date, both at federal and state levels, please read the full memorandum.

PEER Petitions MAHA Commission To Remove PFAS From U.S. Food Chain

On August 13, 2025, Public Employees for Environmental Responsibility (PEER) announced that it petitioned the Make America Healthy Again (MAHA) Commission to remove PFAS from the food chain. PEER notes that its petition highlights three human exposure pathways it asks the MAHA Commission to address:

  • Biosolid fertilizers made from sewage sludge contain high levels of PFAS;
  • The fluorination process used by a large manufacturer of plastic containers creates PFAS in their linings which leach into their contents, including into edible oils and flavorings; and
  • Pesticides containing PFAS are used throughout the country on staple foods such as corn, wheat, kale, spinach, apples, and strawberries.

PEER calls for the MAHA Commission and its individual agency members to take "immediate concerted action to close these PFAS pathways into America's food chain." More information is available in our August 29, 2025, blog item.

Illinois Governor Signs Bill Banning Intentionally Added PFAS In Certain Consumer Products And Requiring IEPA To Prepare Report On Fluoropolymers By August 1, 2027

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 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 atom." The bill defines intentionally added PFAS as "PFAS that are deliberately added during the manufacture of a product if the continued presence of the PFAS is desired in the final product or desired in one of the product's components to perform a specific function in the final product" and specifically excludes "PFAS that are present in the product due to use of water containing PFAS if the manufacturer took no action that resulted in the PFAS being present in the water." More information on the bill and our insightful commentary are available in our August 25, 2025, memorandum.

New York Accepting Comments On Pre-Rulemaking Stakeholder Meeting On PFAS In Apparel Law

On August 25, 2025, the New York State Department of Environmental Conservation (NYS DEC) held a pre-rulemaking stakeholder meeting on its implementation of New York's PFAS in apparel law. NYS DEC is considering clarifying the definitions of apparel and outdoor apparel for severe wet conditions and defining component as "[a]n individual assembled part or a uniquely identifiable material or coating (including ink or dye) that is intended to be included as a part of a finished article of apparel." NYS DEC is considering the following restriction levels:

  • 50 ppm total organic fluorine for all PFAS testing not specified under target analyte list; and
  • 25 to 1,000 parts per billion (ppb) for individual PFAS analytes.

NYS DEC requests feedback on the regulatory definitions and proposed restriction levels. Comments are due September 25, 2025. NYS DEC has posted a recording of the meeting and the slides.

EPA's Spring 2025 Unified Agenda Includes PFAS Rulemakings

On September 4, 2025, OMB published the Trump Administration's Spring 2025 Unified Agenda. EPA's Unified Agenda includes several rulemakings regarding PFAS. More information is available in our September 10, 2025, blog item.

EPA Announces Feed It Onward Initiative

EPA announced on September 5, 2025, the launch of Feed It Onward, "a new national initiative designed to reduce food waste and strengthen food security across America." According to EPA, Feed It Onward connects food donors with communities in need while reducing the environmental impact of food waste in landfills. Feed It Onward will continue to partner with private and public entities to highlight food waste and recovery initiatives and connect food providers with opportunities to reduce food waste.

MAHA Commission Releases Make Our Children Healthy Again Strategy

The U.S. Department of Health and Human Services (HHS) announced on September 9, 2025, that the MAHA Commission released the Make Our Children Healthy Again Strategy, "a sweeping plan with more than 120 initiatives to reverse the failed policies that fueled America's childhood chronic disease epidemic." HHS states that the strategy outlines targeted executive actions to advance gold-standard science, realign incentives, increase public awareness, and strengthen private-sector collaboration. Key focus areas include:

  • Restoring Science and Research: Expanding the National Institutes of Health (NIH) and agency research into chronic disease prevention, nutrition and metabolic health, food quality, environmental exposures, autism, gut microbiome, precision agriculture, rural and tribal health, vaccine injury, and mental health;
  • Historic Executive Actions: Reforming dietary guidelines; defining ultra-processed foods; improving food labeling; closing the Generally Recognized as Safe (GRAS) loophole; raising infant formula standards; removing harmful chemicals from the food supply; increasing oversight and enforcement of direct-to-consumer prescription drug advertising laws; improving food served in schools, hospitals, and to veterans; and reforming Medicaid quality metrics to measure health outcomes;
  • Process Reform and Deregulation: Streamlining organic certification; easing barriers to farm-to-school programs and direct-to-consumer sales; restoring whole milk in schools; supporting mobile grocery and processing units; modernizing FDA drug and device approval; and accelerating EPA approvals for innovative agricultural products;
  • Public Awareness and Education: Launching school-based nutrition and fitness campaigns, Surgeon General initiatives on screen time, prioritizing pediatric mental health, and expanding access to reliable nutrition and health information for parents; and
  • Private Sector Collaboration: Promoting awareness of healthier meals at restaurants, soil health and land stewardship, and community-led initiatives, and scaling innovative solutions to address root causes of chronic disease.

More information is available in our September 15, 2025, blog item.

Responses To DOD Survey On Alternatives To TSCA High Priority Chemicals Due September 26, 2025

The U.S. Department of Defense's (DOD) Office of the Assistant Secretary of Defense for Energy, Installations, and Environment is developing a proof of concept to conduct chemical alternatives assessments (AA) in collaboration with industry. As a first step, DOD will conduct a pilot project to assess alternatives for a chemical of emerging concern to DOD and industry. To help with the chemical selection for the pilot project, DOD is conducting a survey that will allow it to understand better alternative chemical needs. Although the survey is focused on TSCA high priority substances, DOD states that it is open to feedback on other chemicals of concern and their critical applications for the pilot study. DOD notes that the survey is intended solely for informing the AA pilot study selection. Questions, information, or responses should be sent to the program mailbox, osd.pentagon.ousd-atl.mbx.cmrmp@mail.mil. Responses are due September 26, 2025.

New Mexico Will Hold Informational Webinar On Labeling Requirements For Products Containing PFAS

New Mexico's PFAS Protection Act (HB 212) will phase out intentionally added PFAS in certain consumer products before banning intentionally added PFAS in most products on January 1, 2032. The Act also requires manufacturers to report information about intentionally added PFAS by January 1, 2027. The Act states that the New Mexico Environmental Improvement Board may "adopt rules to carry out the provisions of the Per- and Poly-Fluoroalkyl Substances Protection Act, including requiring the labeling of products in English and Spanish." According to New Mexico Environment Department's (NMED) website, on September 25, 2025, at 1:00 p.m. (MDT), NMED will hold an informational webinar on product labeling requirements. To register for the webinar, e-mail NMED-PFAS@env.nm.gov.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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