All regulatory updates
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Maine Chapter 90 PFAS Rule Amendment Establishes CUU Framework
Maine's amended Chapter 90 rule became effective October 7, 2025, establishing the Currently Unavoidable Use (CUU) criteria framework and implementing sales prohibitions for products containing intentionally added PFAS under 38 M.R.S. §1614. The rule details notification requirements, exemptions, and compliance timelines for manufacturers.
EU bans PFAS in firefighting foams under REACH Annex XVII Entry 82
Commission Regulation (EU) 2025/1988 adds Entry 82 to Annex XVII, restricting PFAS in firefighting foams. PFAS is defined as any substance containing at least one fully fluorinated methyl (CF3) or methylene (CF2) carbon atom. The restriction prohibits PFAS at concentrations ≥1 mg/L. Operational and labeling obligations begin October 23, 2026 - PFAS foams may only be used for Class B fires, with emissions reduction requirements and separate collection of unused stock. Full prohibition takes effect October 23, 2030. PFOS, PFOA, and PFHxS covered under the POPs Regulation and certain PFHxA-related substances are exempted from this restriction.
Maine BEP Approves First CUU Determinations for PFAS Products
The Maine Board of Environmental Protection approved two Currently Unavoidable Use (CUU) determinations: (1) cleaning product container internal cartridge valves and (2) cleaning product container vented cap liners. Both determinations are valid until January 1, 2031, allowing continued sale of products containing intentionally added PFAS for these specific applications. Nine other CUU proposals were denied, including cookware/bakeware with PTFE coatings, small kitchen appliances, upholstered furniture, and cosmetic product containers.
NTIA Publishes Updated BABA Compliance and Documentation Requirements
NTIA published updated BABA Compliance and Documentation Requirements guidance for recipients of Broadband Equity, Access, and Deployment (BEAD), Middle Mile, and Tribal Broadband Connectivity Programs. The guidance details documentation requirements, procedures for demonstrating compliance with Buy America Preference, and responsibilities for determining whether products are subject to BABA requirements under 2 CFR Part 184.
DOI publishes updated BABA FAQs guidance document
The Department of the Interior published an updated Build America Buy America Act FAQs document providing guidance on BABA domestic sourcing requirements for infrastructure projects receiving federal financial assistance. The FAQs address common questions about applicability, product coverage, and compliance obligations for DOI-administered programs.
CARB settles with ZIM Integrated Shipping for $12.5M
CARB reached a $12,500,000 settlement with ZIM Integrated Shipping Services Ltd. for violations of CARB's Airborne Toxic Control Measure for vessel fuel requirements. The settlement, processed through ZIM's agent ZIM American Integrated Shipping Services Co. LLC, represents a significant enforcement action for marine vessel fuel compliance in California waters.
EPA issues Sept 30, 2025 primacy extension request templates for state adoption of the 2024 PFAS NPDWR
EPA published primacy extension request documents (memo/templates) to support states, territories, and tribes in requesting additional time to adopt the 2024 PFAS National Primary Drinking Water Regulation (NPDWR) into their primacy programs. This is an implementation support update for drinking-water regulators and utilities; compliance teams should monitor primacy adoption timelines and any associated state-level implementation schedules tied to the NPDWR.
EPA publishes primacy/implementation timeline and extension request materials for the PFAS NPDWR
EPA posted primacy extension request documents and related implementation materials for the PFAS National Primary Drinking Water Regulation (NPDWR). The materials summarize key primacy/implementation milestones for states (including primacy revision package due dates and extension pathways) and provide templates/supporting documents to request primacy extensions. Compliance teams at water utilities and state primacy agencies should use these materials to plan regulatory adoption schedules, monitoring program build-out, and capital planning aligned to the NPDWR implementation timeline.
BIS expands end-user controls to cover 50%-owned affiliates of listed entities
BIS expanded end-user controls to automatically extend Entity List, MEU List, and SDN List license requirements to non-U.S. entities owned 50% or more by listed parties. The 'Affiliates Rule' significantly expands the scope of restricted parties beyond explicitly named entities. IMPORTANT: This rule was suspended for one year effective November 10, 2025, with automatic snap-back scheduled for November 10, 2026.
September 2025 Prop 65 Enforcement Targets PFAS in Consumer Products
In September 2025, 509 Proposition 65 Notices of Violation were issued in California. PFOA and PFOS were specifically cited in enforcement actions targeting waterproof cosmetics, coated fabrics, and packaging materials, demonstrating heightened Prop 65 enforcement activity against PFAS-containing consumer products. Products cited include outerwear, rain jackets, baby bibs, shower curtains, umbrellas, bags, cosmetics, and paper straws. This enforcement trend underscores the need for manufacturers to ensure compliance with Prop 65 warning requirements for products containing listed PFAS chemicals.
EPA releases draft PFAS Abbreviated Data Reporting instructions and UCMR 5 PFAS data reprocessing notice to support PFAS NPDWR implementation
As part of PFAS NPDWR implementation support, EPA posted implementation updates including (1) a draft document for PFAS Abbreviated Data Reporting instructions and (2) a notice regarding release/reprocessing of UCMR 5 PFAS data and the SDWIS state upload process. These materials are relevant for public water systems and primacy agencies preparing monitoring/data submission and leveraging UCMR 5 data for compliance planning and administration under the PFAS drinking water rule.
EPA releases primacy extension request documents/templates for 2024 PFAS NPDWR implementation
EPA published primacy extension request support materials (memo and templates) to help states/primacy agencies request additional time to adopt the 2024 PFAS National Primary Drinking Water Regulation (NPDWR). The memo reiterates primacy timing mechanics (e.g., with an approved extension, primacy application packages are due no later than April 26, 2028; without an extension, due April 27, 2026 as noted in the memo). This is compliance-relevant for state drinking-water regulators and public water systems tracking state adoption/primacy timelines and associated implementation planning.
EPA releases primacy extension templates and draft PFAS abbreviated data reporting instructions for PFAS NPDWR implementation
EPA posted new implementation tools for the PFAS National Primary Drinking Water Regulation (NPDWR), including (1) primacy extension request templates for primacy agencies seeking additional time to revise drinking water programs and (2) draft PFAS Abbreviated Data Reporting Instructions. These materials are intended to support state primacy agencies and public water systems in implementing program revisions and data reporting associated with the PFAS NPDWR.
EPA publishes primacy extension request templates to support PFAS NPDWR state implementation
EPA published implementation resources for the PFAS NPDWR, including templates intended to help primacy agencies request extensions for primacy revision actions. State primacy agencies and regulated water systems should use these materials to plan state adoption/primacy timelines and coordinate implementation planning.
EPA proposes revisions to TSCA procedures for chemical risk evaluation (risk evaluation ‘Framework Rule’)
EPA proposed amendments to the TSCA risk evaluation procedures rule (the ‘Framework Rule’) that governs how EPA conducts existing-chemical risk evaluations. The proposal (per EPA’s release) would adjust key procedural elements such as conditions-of-use determinations and other evaluation process components, and opens a public comment period. Compliance teams should assess how the proposed procedural changes could affect the scope, pace, and content of future TSCA risk evaluations relevant to their chemical portfolios and consider submitting comments.
EPA proposes revisions to procedures for chemical risk evaluation under TSCA (Federal Register proposal dated Sept. 23, 2025)
EPA issued a proposed rule to amend procedures for conducting chemical risk evaluations for existing chemicals under TSCA. This proposal would revise the risk evaluation framework and could affect how companies plan for risk evaluation scope, data submissions, use categorization, and downstream risk management implications. Compliance teams should review the proposal and consider participating in the public comment process for impacts to ongoing and future TSCA risk evaluations.
CPPA/OAL approve finalized CCPA regulations package covering cybersecurity audits, risk assessments, and ADMT (plus updates to existing CCPA regs)
The CPPA announced approval of a major CCPA/CPRA regulations package (approved by OAL) that includes requirements and frameworks for cybersecurity audits, risk assessments, and rules governing automated decisionmaking technology (ADMT), along with updates to existing CCPA regulations. This is directly relevant to Vendor Cybersecurity & Data Privacy because these obligations commonly flow down into vendor/service-provider governance: businesses will need stronger documentation of cybersecurity programs, assessment processes, audit readiness, and risk management for processing activities often performed by vendors (e.g., cloud/SaaS processors). The CPPA announcement states an effective date of Jan 1, 2026, with staged compliance timelines referenced for audit certifications, risk assessment submissions/attestations, and ADMT significant-decision obligations.
EPA proposes revisions to procedures for conducting TSCA risk evaluations for existing chemicals (Framework Rule)
EPA announced a proposed rule to revise the process/procedures for conducting TSCA risk evaluations for chemicals already in commerce (existing chemicals), intended to increase efficiency and better protect health and the environment. The proposal opens a public comment period (duration described by EPA in the news release). Compliance teams should assess how potential changes could affect scope, pace, and data expectations for TSCA risk evaluations, and consider submitting comments via the associated docket if affected.
EPA proposes amendments to TSCA risk evaluation framework rule (procedures for chemical risk evaluation)
EPA announced a proposed rule to revise the procedures for conducting TSCA risk evaluations for existing chemicals (the TSCA risk evaluation framework/procedural rule). The proposal describes changes affecting how EPA makes risk determinations (including around conditions of use and exposure pathways), treatment of occupational exposure controls (e.g., PPE/engineering controls), and related procedural/definition updates. Companies with substances undergoing TSCA risk evaluation should assess potential impacts on evaluation scope and assumptions and consider submitting comments in the associated docket once the proposal is published in the Federal Register.
OEHHA proposes NSRL safe harbor levels for 1‑bromopropane and diethanolamine (dermal) and extends comment deadline
OEHHA issued a proposed rulemaking to amend Title 27, California Code of Regulations, section 25705 (No Significant Risk Levels for carcinogens) to add new safe harbor NSRLs: 1‑bromopropane at 54 µg/day and diethanolamine (dermal exposure only) at 6.4 µg/day. OEHHA also issued an extension notice moving the public comment deadline to November 7, 2025. If finalized, these NSRLs would affect Proposition 65 warning determinations and risk assessments for products or workplaces involving these substances, particularly for dermal exposure scenarios for diethanolamine.