Chemicals
Overview
Crowell & Moring's chemicals team helps companies to bring their chemical products to market and keep them there. We also work closely with our clients to anticipate, prepare for, and respond to challenges and threats to the chemistries they rely on.
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Insights
Client Alert | 5 min read | 10.02.26
California AB 1603: What Pesticide Registrants Need to Know About New PFAS Disclosure Requirements
California Assembly Bill 1603 amends the Food and Agricultural Code by directing DPR to take several concrete steps no later than January 1, 2028 to identify and disclose PFAS pesticide ingredients in California-registered pesticides. DPR must now flag whether each registered pesticide contains PFAS pesticide ingredients in its online pesticide use reporting database, designate PFAS as a searchable category of interest within that database, and incorporate PFAS pesticide use trends into its annual pesticide use report and related reporting documents on an ongoing basis. Separately, DPR must compile and publish on its website a complete list of all registered pesticides containing PFAS pesticide ingredients and deliver that list to every county agricultural commissioner in California. After the initial publication, DPR is required to update the list and redistribute it to all county commissioners within 60 calendar days whenever a new PFAS-containing pesticide is registered.
Client Alert | 5 min read | 09.23.26
Fifth Circuit Vacates EPA's Methylene Chloride Rule: A Landmark Decision Reshaping TSCA Section 6
Client Alert | 5 min read | 08.26.26
D.C. Circuit Upholds Designation of PFOA and PFOS as CERCLA Hazardous Substances
Representative Matters
- We advised several global manufacturers and represented their interests on Capitol Hill during negotiations on TSCA modernization and the debate and discussions leading up to enactment of the Frank R. Lautenberg Chemical Safety for the 21st Century Act.
- We have assisted many clients in understanding and complying with the requirements of “New TSCA,” including "Inventory reset" reporting and reporting on nanoscale materials.
- We regularly assist clients in obtaining new product clearances under TSCA, including novel product categories such as biotechnology products and products employing nanotechnology. We also have negotiated multiple TSCA section 5(e) consent orders and section 5(a)(2) significant new use rules for new chemicals, when needed to secure their access to the U.S. market.
- We routinely counsel clients on labeling and testing requirements, import and export requirements, new product development, reporting and recordkeeping requirements, and the applicability of new regulations and evolving agency guidance.
- We advise companies on legislative and regulatory initiatives at the state, federal and international levels concerning various chemicals of concern, including perfluorinated compounds, brominated flame retardants, bisphenol-A, and others.
- We assist clients in preparing for and complying with emerging state regulatory programs governing chemical products, such as California’s Safer Consumer Product Regulations and Maine’s Act to Protect Children’s Health and the Environment from Toxic Chemicals in Toys and Children’s Products.
- We often assist companies to defend themselves against enforcement actions brought by EPA and state regulatory agencies, and we frequently help companies to mitigate their risk of civil monetary penalties under TSCA by effectively using EPA’s Audit Policy, New Owner Policy, and Small Business Compliance Policy.
- We have performed product regulatory due diligence in connection with many acquisitions and sales of chemical companies, business units, and product lines.
- Finally, because the chemical industry is global, we assist clients through our Brussels office in identifying and complying with their obligations under the European Union’s Regulation Concerning the Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) and related legislation in the EU.
Contact
Insights
Client Alert | 5 min read | 10.02.26
California AB 1603: What Pesticide Registrants Need to Know About New PFAS Disclosure Requirements
California Assembly Bill 1603 amends the Food and Agricultural Code by directing DPR to take several concrete steps no later than January 1, 2028 to identify and disclose PFAS pesticide ingredients in California-registered pesticides. DPR must now flag whether each registered pesticide contains PFAS pesticide ingredients in its online pesticide use reporting database, designate PFAS as a searchable category of interest within that database, and incorporate PFAS pesticide use trends into its annual pesticide use report and related reporting documents on an ongoing basis. Separately, DPR must compile and publish on its website a complete list of all registered pesticides containing PFAS pesticide ingredients and deliver that list to every county agricultural commissioner in California. After the initial publication, DPR is required to update the list and redistribute it to all county commissioners within 60 calendar days whenever a new PFAS-containing pesticide is registered.
Client Alert | 5 min read | 09.23.26
Fifth Circuit Vacates EPA's Methylene Chloride Rule: A Landmark Decision Reshaping TSCA Section 6
Client Alert | 5 min read | 08.26.26
D.C. Circuit Upholds Designation of PFOA and PFOS as CERCLA Hazardous Substances
Insights
EPA’s Shift In Chemical and Hazardous Materials Regulation and What Retailers Can Expect
|10.27.21
Crowell & Moring’s Retail & Consumer Products Law Observer
Insights
Client Alert | 5 min read | 10.02.26
California AB 1603: What Pesticide Registrants Need to Know About New PFAS Disclosure Requirements
California Assembly Bill 1603 amends the Food and Agricultural Code by directing DPR to take several concrete steps no later than January 1, 2028 to identify and disclose PFAS pesticide ingredients in California-registered pesticides. DPR must now flag whether each registered pesticide contains PFAS pesticide ingredients in its online pesticide use reporting database, designate PFAS as a searchable category of interest within that database, and incorporate PFAS pesticide use trends into its annual pesticide use report and related reporting documents on an ongoing basis. Separately, DPR must compile and publish on its website a complete list of all registered pesticides containing PFAS pesticide ingredients and deliver that list to every county agricultural commissioner in California. After the initial publication, DPR is required to update the list and redistribute it to all county commissioners within 60 calendar days whenever a new PFAS-containing pesticide is registered.
Client Alert | 5 min read | 09.23.26
Fifth Circuit Vacates EPA's Methylene Chloride Rule: A Landmark Decision Reshaping TSCA Section 6
Client Alert | 5 min read | 08.26.26
D.C. Circuit Upholds Designation of PFOA and PFOS as CERCLA Hazardous Substances







