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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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The chemical industry is subject to complex and ever-evolving laws and regulations. New standards governing the production and use of chemicals are implemented every year worldwide, and existing laws and regulations are constantly changing to keep pace with new information and scientific advancements. Chemical Industry Regulatory Update provides a monthly digest of recent legislative and regulatory developments and related industry news.

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Global Adhesive and Sealant Industry Heads to London for WAC 2026

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The World Adhesive &amp; Sealant Conference and EXPO (WAC 2026) will bring together stakeholders from across the global adhesive and sealant value chain September 16–18, 2026, at the Queen Elizabeth II Centre in London, England. Built around the theme “Reinventing the Future,” the conference will feature expert presentations, cross-sector dialogue, emerging technologies, and international networking focused on how the industry is responding to—and actively shaping—regulatory, market, sustainability, and technological change. <a href="https://www.wac2026.org/">Register online</a>.

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Short Course on Adhesive Testing Heads to Baltimore September 21–23

Adhesives are everywhere and continue to replace mechanical fasteners in diverse applications from medical to aerospace. This course will provide background on universal adhesive and adhesion testing protocols for determining chemical composition, molecular architecture, mechanical, thermal, and rheological properties, as well as technology-specific test methods for PSAs, Reactive, waterborne, and sealants from experts in the field. To view the full agenda, please visit <a href="https://www.ascouncil.org/events/2026-testing-short-course">https://www.ascouncil.org/events/2026-testing-short-course</a>.

DOW Suspends CMMC Program Phase 2; Contractor Obligations Remain

The Department of War (DOW) has suspended the upcoming phase of its Cybersecurity Maturity Model Certification (CMMC) program designed to increase cybersecurity standards and compliance for the defense industrial base. In a <a href="https://dodcio.defense.gov/Portals/0/Documents/Library/CMMC-ReformMemo.pdf">memorandum</a> issued on July 13, DOW announced the suspension of Phase 2 of the CMMC program, scheduled to begin this November, while the agency examines whether the program aligns with its priorities. Although the memorandum pauses implementation of Phase 2 requirements, it makes clear that contractors must continue to adhere to CMMC Phase 1 requirements, including Levels 1 and 2 self-assessments. <a href="https://www.thompsonhine.com/insights/dow-suspends-cmmc-program-phase-2-contractor-obligations-remain/">Keep reading</a>.

DOJ and DHS Release Trade Fraud Enforcement Resource Guide, Signaling Heightened Enforcement

On July 14, 2026, the Department of Justice (DOJ) and Department of Homeland Security (DHS) jointly issued <a href="https://www.justice.gov/fraud/media/1452331/dl?inline">A Resource Guide to Trade Fraud Enforcemen</a>t (the “Resource Guide”) through the newly established Trade Fraud Task Force, which includes DOJ's National Fraud Enforcement Division, DHS Homeland Security Investigations (HSI), and U.S. Customs and Border Protection (CBP). Although the Resource Guide is not legally binding, it sends a clear enforcement-intent signal: DOJ now views customs and trade violations as serious civil and criminal matters, not merely administrative infractions. The guide outlines the statutory framework governing trade fraud while providing practical insight into how DOJ and DHS investigate and pursue these matters. It also may help prosecutors rebut arguments that targets and defendants were unaware of their legal obligations. For companies and their counsel, the message is clear: the federal government is investing in coordinated, aggressive trade fraud enforcement and expects robust compliance throughout the supply chain. <a href="https://www.thompsonhine.com/insights/doj-and-dhs-release-trade-fraud-enforcement-resource-guide-signaling-heightened-enforcement/">Learn more</a>.

USTR Conducts Section 301 Investigations into Forced Labor Practices and Proposes Tariffs of 10% to 12.5% on 60 Trade Partners

On March 12, 2026, the U.S. Trade Representative (“USTR”) launched Section 301 investigations into 60 trade partners to determine whether they have failed to impose and effectively enforce a prohibition on the importation of goods produced with forced labor. The investigations, conducted pursuant to Section 301of the Trade Act of 1974, included China, the European Union, India, and Mexico. A full list of the trade partners involved is provided in Annex A of the Federal Register <a href="https://www.govinfo.gov/content/pkg/FR-2026-03-17/pdf/2026-05151.pdf">Notice of Initiation</a>. <a href="https://www.thompsonhine.com/insights/ustr-conducts-section-301-investigations-into-forced-labor-practices-and-proposes-tariffs-of-10-to-12-5-on-60-trade-partners/">Read more</a>.

Supreme Court Rules FIFRA Preempts State Failure-to-Warn Claims

On June 25, the U.S. Supreme Court issued its opinion in Monsanto Co. v. Durnell, No. 24-1068, 609 U.S. _ (2026), resolving a long-standing circuit split on whether the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) preempts state-law failure-to-warn claims against pesticide manufacturers.

Glyphosate – the active ingredient in Roundup – is the most commonly used pesticide in the United States, with approximately 300 million pounds applied annually. EPA has regulated glyphosate since 1974 and has repeatedly concluded that glyphosate is “not likely to be carcinogenic to humans,” issuing assessments to that effect in 1991, 2005, 2015, and 2017. In 2015, however, the International Agency for Research on Cancer (IARC) classified glyphosate as “probably carcinogenic to humans.” EPA reexamined the issue in 2017 and 2019 following IARC’s classification but adhered to its long-standing position. <a href="https://www.thompsonhine.com/insights/supreme-court-rules-fifra-preempts-state-failure-to-warn-claims/">Explore further</a>.

CBP Launches Phase 2 of the IEEPA Tariff Refund Process and Confirms Development of Phase 3

On June 23, 2026, U.S. Customs and Border Protection (“CBP”) published <a href="https://content.govdelivery.com/accounts/USDHSCBP/bulletins/41d65dd?reqfrom=share">Cargo Systems Messaging Service (“CSMS”) #69035485</a>, confirming that Phase 2 of the process for refunding duties paid by importers of record under the International Emergency Economic Powers Act (“IEEPA”) will be deployed in the Automated Commercial Environment (“ACE”) Portal on June 29, 2026. CBP unveiled the refund process, known as the Consolidated Administration and Processing of Entries (“CAPE”), in a <a href="https://filehost.thompsonhine.com/uploads/CBP_-_March_12_Updated_Lord_Declaration_6191.pdf">March 12, 2026 declaration</a> to the U.S. Court of International Trade (“CIT”), confirming that the IEEPA tariff refund process would be implemented in multiple phases (see <a href="https://www.thompsonhinesmartrade.com/2026/03/cbp-reports-progress-on-ieepa-tariff-refund-process/">Update of March 13, 2026</a>). <a href="https://www.thompsonhine.com/insights/cbp-launches-phase-2-of-the-ieepa-tariff-refund-process-and-confirms-development-of-phase-3/">Continue reading</a>.

Our Business Law Update keeps you up to date on legal issues that impact public and private companies on a local, national and global basis. Articles in this issue include insights on labor &amp; employment, intellectual property, new ventures, and business restructuring. <a href="https://www.thompsonhine.com/insights/business-law-update-july-2026/">Read more</a>.

USTR Imposes 25% Section 301 Tariff on Certain Imports from Brazil

On July 15, 2026, the Office of the U.S. Trade Representative (USTR) announced that, pursuant to Section 301 of the Trade Act of 1974, it was imposing a 25% tariff on certain imports of Brazilian goods. The announcement came at the direction of President Donald Trump following an investigation and determination by the USTR that certain Brazilian measures related to: (i) digital trade and electronic payment services; (ii) unfair preferential tariffs; (iii) anti-corruption interference; (iv) intellectual property protection; (v) ethanol market access; and (vi) illegal deforestation “are unreasonable and burden or restrict the commerce of American farmers, workers, innovators, and exporters.”

The Federal Register <a href="https://ustr.gov/sites/default/files/files/Issue_Areas/Enforcement/Section%20301/Brazil%20301%20Final%20Action%20FRN%207-15-2026%20final.pdf">Notice of Action</a> states that this additional duty is applicable to all imports of Brazil entered into the United States for consumption, or withdrawn from warehouse for consumption, on or after 12:01 EDT on July 22, 2026. These additional tariffs do not apply to informational materials, donations, accompanied baggage, all articles and parts of articles subject to tariffs under Section 232 of the Trade Expansion Act of 1962, and certain products identified by their Harmonized Tariff Schedule of the United States (HTSUS) subheading in Annex I and II to the Notice of Action. <a href="https://www.thompsonhinesmartrade.com/2026/07/ustr-imposes-25-section-301-tariff-on-certain-imports-from-brazil/">Learn more</a>.

CIT Orders CBP to Process IEEPA Tariff Refunds for Phase 3 “Finally Liquidated” Entries

On July 17, 2026, U.S. Court of International Trade (CIT) Senior Judge Richard Eaton, <a href="https://filehost.thompsonhine.com/uploads/CIT_July_21_IEEPA_Order_1081.pdf">issued an order</a>, which was made available today, directing U.S. Customs and Border Protection (CBP) to “reliquidate, without regard to IEEPA [the International Emergency Economic Powers Act] duties, any and all of Plaintiffs’ entries that have been liquidated for more than 80 days and on which Plaintiffs made estimated deposits pursuant to IEEPA.” This order follows the recent transfer to Judge Eaton’s docket of more than 3,700 cases filed with the CIT seeking refunds of amounts deposited as IEEPA duties ruled unconstitutional by the U.S. Supreme Court earlier this year. While the U.S. government through CBP voluntarily established the Consolidated Administration and Processing of Entries (CAPE) system for processing IEEPA tariff refunds, the government’s position had consistently been that a court order directing the reliquidation of entries whose liquidation had become final would be necessary to provide authority to reliquidate these “finally liquidated” entries – i.e., entries that have been liquidated for more than 90 days and thus beyond the period for reliquidation set out in 19 U.S.C. § 1501. According to Judge Eaton’s July 17 order, this “order provides the Government with that legal authority.” This order only applies to companies that have filed cases seeking IEEPA tariff refunds at the CIT. <a href="https://www.thompsonhinesmartrade.com/2026/07/cit-orders-cbp-to-process-ieepa-tariff-refunds-for-phase-3-finally-liquidated-entries/">Keep reading</a>.

Trump Administration Imposes Section 338 Tariffs on Certain Imports from Canada

On July 20, 2026, President Donald Trump issued three Proclamations pursuant to Section 338 of the Tariff Act of 1930 imposing 50% tariffs on imports of certain Canadian goods. The Proclamations, <a href="https://www.whitehouse.gov/presidential-actions/2026/07/imposing-additional-duties-to-offset-canadian-discrimination-against-the-commerce-of-the-united-states-with-respect-to-dairy/">“Imposing Additional Duties to Offset Canadian Discrimination Against the Commerce of the United States with Respect to Dairy,</a>” “<a href="https://www.whitehouse.gov/presidential-actions/2026/07/imposing-additional-duties-to-offset-canadian-discrimination-against-the-commerce-of-the-united-states-with-respect-to-alcoholic-beverages/">Imposing Additional Duties to Offset Canadian Discrimination Against the Commerce of the United States with Respect to Alcoholic Beverages,</a>” and “<a href="https://www.whitehouse.gov/presidential-actions/2026/07/imposing-additional-duties-to-offset-canadian-discrimination-against-the-commerce-of-the-united-states-with-respect-to-motor-vehicles/">Imposing Additional Duties to Offset Canadian Discrimination Against the Commerce of the United States with Respect to Motor Vehicles</a>,” were made “in response to Canada’s discriminatory treatment of American products.” The tariffs are set to take effect on August 19.

The tariffs under Section 338 cover products such as wine, hockey sticks, and cement. The tariffs apply to all covered goods regardless of whether a good originates under the U.S.-Mexico-Canada Agreement (USMCA). These Section 338 tariffs will not apply to energy, potash, products subject to tariffs under Section 232, and certain other goods, such as fish or critical minerals. The tariffs will take effect 30 days after signing and “are designed to offset the burden and disadvantage on U.S. commerce from Canada’s discrimination.” <a href="https://www.thompsonhinesmartrade.com/2026/07/trump-administration-imposes-section-338-tariffs-on-certain-imports-from-canada/">Explore further</a>.

USTR Implements Tariffs in Section 301 Forced Labor Investigations

On July 23, 2026, the Office of the U.S. Trade Representative (USTR) announced in a <a href="https://ustr.gov/sites/default/files/files/Press/Releases/2026/FLIP%20301%20Investigation%20Final%20Action%20FRN%207-23-26%20FINAL.pdf">Notice of Action</a> its final action in the Section 301 investigation of 60 economies for “their failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor.” Under Section 301 of the Tariff Act of 1974, the USTR has made the following determinations:

10 percent is the appropriate rate of Section 301 duties for investigated economies that (i) impose a forced labor import prohibition; (ii) have committed to impose and enforce such a prohibition through an Agreement on Reciprocal Trade; or (iii) have imposed a partial regime with the effect of preventing the importation of certain forced labor goods. These economies are: Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Sri Lanka, Trinidad and Tobago, and the United Kingdom;

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10 percent or 12.5 percent, net of Most-Favored-Nation (MFN) rate is the appropriate rate of Section 301 duties for certain products of the European Union, Taiwan, Japan, Korea, and Switzerland that are not otherwise exempted, as explained in greater detail in the Federal Register Notice; and

12.5 percent is the appropriate rate of Section 301 duty for all other investigated economies. <a href="https://www.thompsonhinesmartrade.com/2026/07/ustr-to-implement-tariffs-in-section-301-forced-labor-investigations/">Read more</a>.

Check out the latest <a href="https://www.thompsonhine.com/insights/employment-legislation-outlook-august-2026/">Employment Legislation Outlook</a>. This monthly digest is designed to keep you apprised of upcoming major state law changes in areas including paid sick and safe leave laws, family and parental leave, recreational and medicinal marijuana use, workplace gun laws, asking candidates about salary history and unpredictable scheduling.

Looking for Adhesive &amp; Sealant Training?

ASC’s <a href="https://www.ascouncil.org/certificate-program">Training Academy Certificate Program</a> offers a convenient and cost-effective, web-based method of workforce training ideal for new or new to a role staff and professionals. A variety of flexible and affordable subscription options are available.

For more information, contact the editor, <a href="https://www.thompsonhine.com/professionals/devin-a-barry/">Devin A. Barry</a>, or any of the authors.

Chemical Industry Regulatory Update is compiled by Thompson Hine lawyers on behalf of <a href="https://www.ascouncil.org/">The Adhesive and Sealant Council</a>. It should not be construed as legal advice, and the views and opinions expressed herein are those of the authors and do not necessarily reflect those of the ASC or its members.

Chemical Industry Regulatory Update – August 2026

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