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Stronger Dollar Pushes Trade Agreements Act Thresholds Down

Client Alert | less than 1 min read | 12.17.15

On December 15, 2015, the U.S. Trade Representative published its biennial readjustment of the Trade Agreements Act thresholds expressed in "special drawing rights." The new dollar thresholds, effective for 2016-2017, will be approximately 6.4% lower than the current thresholds, going to $191,000 for most covered supply contracts and $7,358,000 for most covered construction contracts, with other adjusted thresholds applicable to certain free trade agreements.


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Client Alert | 3 min read | 05.28.26

PFAS Regulatory Alert: EPA Rolls Back RCRA Proposed Rule on “Hazardous Waste” but Does Not Disturb Proposed RCRA Rule on PFAS

Earlier this month, the U.S. Environmental Protection Agency (EPA) withdrew a February 2024 Biden administration proposed rule, “Definition of Hazardous Waste Applicable to Corrective Action for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the narrower regulatory definition. Now, EPA is maintaining the status quo for corrective action under RCRA. However, EPA’s withdrawal of its proposed RCRA hazardous waste definition makes no mention of its corresponding proposal from 2024 to list nine per- and polyfluoroalkyl substances (PFAS) as RCRA hazardous constituents.[2] This disjointed withdrawal, while providing some certainty for regulated entities, does not resolve how EPA plans to address PFAS under the RCRA program....