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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 8 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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Final Week to Propose a Topic for the 2026 ASC Annual Convention &amp; EXPO

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ASC’s Annual Convention takes place in April of 2026 in “Music City” – Nashville, Tennessee. This is the largest official gathering of the industry in North America, and ASC invites you to present a topic of expertise to the industry. Please submit BY DECEMBER 12th (this Friday). Your insights are vital to the success and continued advancement of our industry, making this a powerful opportunity for your company to showcase its knowledge and contribute to the community.

Learn more <a href="https://form.jotform.com/251945438971166">ONLINE</a> or download a <a href="https://assets-002.noviams.com/novi-file-uploads/asc/PDFs/Conv26_Call_for_Speakers_Handout_PROOF_7-23-25-FINAL.pdf">handout</a>.

DOJ Announces Charges for False Country-of-Origin Claims and Tariff Evasion Through Undervaluation

The Department of Justice (DOJ) in September <a href="https://www.justice.gov/opa/pr/two-companies-and-three-executives-indicted-fraudulently-selling-chinese-forklifts-us">announced</a> the unsealing of an indictment charging two Colorado companies and three executives with a multiyear scheme to sell Chinese made forklifts to the U.S. government while falsely representing that the equipment was manufactured in the U.S. and compliant with the Buy American Act (BAA) and the Trade Agreements Act (TAA). The charges span 27 counts, including conspiracy to commit wire fraud, wire fraud, making materially false statements, and conspiracy to defraud the United States. The investigation was led by the DOJ Antitrust Division’s Procurement Collusion Strike Force in coordination with a cross-agency team including the U.S. Army Criminal Investigative Division, Defense Criminal Investigative Service, U.S. Air Force Office of Special Investigations, U.S. General Services Administration Office of Inspector General, U.S. Department of Homeland Security Office of Inspector General, Department of Veterans Affairs Office of Inspector General, and Defense Contract Audit Agency. <a href="https://www.thompsonhine.com/insights/doj-announces-charges-for-false-country-of-origin-claims-and-tariff-evasion-through-undervaluation/">Learn more</a>.

Recent Self-Reporting Case Involving Potential FTO Payments Signals Urgent Compliance Risks for Global Companies

On November 7, 2025, Texas-headquartered Kodiak Gas Services (Kodiak Gas) filed an amended quarterly report with the Securities and Exchange Commission (SEC) disclosing that an internal investigation undertaken on behalf of the company had found that “certain payments likely were made” to individuals likely associated with a Foreign Terrorist Organization (FTO). According to the filing, Kodiak Gas received a report in early 2025 regarding payments to local government officials in Mexico that had commenced prior to the company’s acquisition of its Mexican affiliate in April 2024. In response to this report, Kodiak Gas retained outside counsel to conduct an internal investigation, which ultimately determined that certain payments were likely made to persons associated with an organization designated as a Specially Designated Global Terrorist (SDGT). Specifically, the investigation found that the payments appear to have been made in order to secure protection for employees of the Mexican affiliate company and safeguard their access to work sites. Kodiak Gas subsequently sold its Mexican operations and affiliate in September 2025. <a href="https://www.thompsonhine.com/insights/recent-self-reporting-case-involving-potential-fto-payments-signals-urgent-compliance-risks-for-global-companies/">Explore further</a>.

New York LLC Transparency Act Scheduled To Take Effect on January 1, 2026

New York has enacted the New York LLC Transparency Act (NY LLCTA), introducing beneficial ownership disclosure requirements for both domestic and foreign limited liability companies (LLCs) doing business in the state, but its potential impact is still undetermined. The law, which takes effect on January 1, 2026, had initially been modeled on the federal Corporate Transparency Act (CTA). In response to legal challenges, <a href="https://www.thompsonhine.com/insights/fincen-scales-back-corporate-transparency-act-interim-final-rule-issued/">FinCEN issued an interim final rule in March</a> that effectively revised the definition of “reporting company” for purposes of the CTA to mean only those entities that are formed under the laws of a foreign country and that have registered to do business in any state, which then exempted all entities created in the U.S. from beneficial ownership information (BOI) reporting requirements. The new definition would also have applied to the NY LLCTA, effectively exempting entities created in the U.S. To prevent this, the New York Legislature in June passed a bill, SB S8432, to replace the definitions of “reporting company,” “exempt company,” and “beneficial owner” to define them independently from the definitions applied by the CTA, as interpreted by FinCEN. That bill is still waiting for New York Governor Kathy Hochul’s signature. In the interim, the New York Department of State has not yet made available to the public an official New York website to accept reports and meaningful guidance on the subject has not been circulated.

Under the NY LLCTA, LLCs formed or registered to do business in New York before January 1, 2026, have until January 1, 2027, to file their initial BOI report. LLCs formed or registered to do business in New York on or after January 1, 2026, must file BOI reports within 30 days of formation or registration. <a href="https://www.thompsonhine.com/insights/new-york-llc-transparency-act-scheduled-to-take-effect-on-january-1-2026/">Explore further</a>.

USPTO Launches Streamlined Claim Set Pilot Program: A New Path to Faster Examination

The USPTO has opened a new pathway in the examination queue with its Streamlined Claim Set Pilot Program. Effective October 27, 2025, this limited-duration initiative allows qualifying applications to move “out of turn” to a first Office action, offering potential advantages for applicants willing to narrow their claim sets and meet strict procedural requirements—while requiring careful navigation of tradeoffs and procedural pitfalls. <a href="https://www.thompsonhine.com/insights/uspto-launches-streamlined-claim-set-pilot-program-a-new-path-to-faster-examination/">Continue reading</a>.

California’s Climate Risk Rules on Pause – Compliance Planning Should Not Be

Major developments recently unfolded in the implementation of California’s Climate Corporate Data Accountability Act (SB 253) and Climate-Related Financial Risk Act (SB 261) (collectively, the “200s” or “climate disclosure laws”). On November 18, the California Air Resources Board (CARB) hosted its third public workshop to update stakeholders on the rulemaking process and solicit public feedback on proposed regulations. During the workshop, the U.S. Court of Appeals for the Ninth Circuit in Chamber of Commerce of the United States, et al. v. California Air Resources Board, et al., 2:24-cv-00801 (9th Cir. 2025), froze enforcement of SB 261, pending appeal, but declined to stay SB 253. In this bulletin, we break down the ongoing status of litigation involving California’s climate disclosure laws and recap key insights from CARB’s third public workshop. For an overview of the requirements of California’s climate disclosure laws, please see our August 2025 bulletin <a href="https://www.thompsonhine.com/insights/recapping-carbs-second-public-workshop-for-californias-climate-disclosure-laws/">“Recapping CARB’s Second Public Workshop for California’s Climate Disclosure Laws.”</a> <a href="https://www.thompsonhine.com/insights/californias-climate-risk-rules-on-pause-compliance-planning-should-not-be/">Read more</a>.

White House Announces Details on U.S.-South Korea Trade Deal

On November 14, 2025, the White House released a <a href="https://www.whitehouse.gov/fact-sheets/2025/11/joint-fact-sheet-on-president-donald-j-trumps-meeting-with-president-lee-jae-myung/">Fact Sheet</a> providing details on The Korea Strategic Trade and Investment deal first announced in July 2025. A released Fact Sheet provides an overview of the main issues. <a href="https://www.thompsonhinesmartrade.com/2025/11/white-house-announces-details-on-u-s-south-korea-trade-deal/">Keep reading</a>.

United States, Switzerland and Liechtenstein Agree to Framework Agreement on Reciprocal Trade

On November 14, 2025, the United States, the Swiss Confederation (Switzerland), and the Principality of Liechtenstein (Liechtenstein) agreed to a framework for negotiations on an Agreement on Reciprocal Trade. While representatives from the three countries continue to negotiate the formal agreement and hope to conclude any agreement during the first quarter of 2026. <a href="https://www.thompsonhinesmartrade.com/2025/11/united-states-switzerland-and-liechtenstein-agree-to-framework-agreement-on-reciprocal-trade/">Read more</a>.

United States and El Salvador Reach Framework Agreement on Reciprocal Trade

On November 13, 2025, the United States and the Republic of El Salvador entered a framework for an <a href="https://www.whitehouse.gov/briefings-statements/2025/11/joint-statement-on-framework-for-united-states-el-salvador-agreement-on-reciprocal-trade/">Agreement on Reciprocal Trade</a>. The Agreement aims to strengthen the countries’ economic partnership established in 2006 under the Dominican Republic–Central America–United States Free Trade Agreement (“CAFTA-DR”). The framework agreement is one of several reached by the Trump administration in an effort to strengthen supply chains and “deepen bilateral trade and investment cooperation to provide American exporters with greater access to markets in Central and South America.” <a href="https://www.thompsonhinesmartrade.com/2025/11/united-states-and-el-salvador-reach-framework-agreement-on-reciprocal-trade/">Keep reading</a>.

United States and Guatemala Reach Framework Agreement on Reciprocal Trade

On November 13, 2025, the United States and the Republic of Guatemala entered a framework for an Agreement on Reciprocal Trade. The Agreement aims to strengthen the countries’ economic partnership established in 2006 under the Dominican Republic–Central America–United States Free Trade Agreement (“CAFTA-DR”). While representatives from both countries continue to negotiate and finalize the formal agreement, the <a href="https://www.whitehouse.gov/briefings-statements/2025/11/joint-statement-on-framework-for-united-states-guatemala-agreement-on-reciprocal-trade/">Joint Statement</a> includes some key terms. <a href="https://www.thompsonhinesmartrade.com/2025/11/united-states-and-guatemala-reach-framework-agreement-on-reciprocal-trade/">Read more</a>.

United States and Argentina Reach Framework Agreement on Reciprocal Trade

On November 13, 2025, the United States and the Argentine Republic entered a framework for an Agreement on Reciprocal Trade. The Agreement seeks “to drive long-term growth, expand opportunity, and create a transparent and rules-based environment for commerce and innovation.” While representatives from both countries continue to negotiate and finalize the formal agreement, it will contain certain key terms. <a href="https://www.thompsonhinesmartrade.com/2025/11/united-states-and-argentina-reach-framework-agreement-on-reciprocal-trade/">Continue reading</a>.

United States and Ecuador Reach Framework Agreement on Reciprocal Trade

According to a <a href="https://www.whitehouse.gov/briefings-statements/2025/11/joint-statement-on-framework-for-united-states-ecuador-agreement-on-reciprocal-trade/">Joint Statement</a> issued by the White House on November 13, 2025, the United States and the Republic of Ecuador have entered into a Framework for an Agreement on Reciprocal Trade to “provide access to each other’s markets and increase alignment on economic and national security matters.” As noted in a separate <a href="https://www.whitehouse.gov/fact-sheets/2025/11/fact-sheet-president-donald-j-trump-announces-historic-trade-deals-with-western-hemisphere-trading-partners/">White House Fact Sheet</a>, the bilateral framework agreement with Ecuador is one of several reached by the Trump administration in an effort to strengthen commercial and economic ties with a trading partner, and the latest in a series of such agreements with countries in Central America and South America. <a href="https://www.thompsonhinesmartrade.com/2025/11/united-states-and-ecuador-reach-framework-agreement-on-reciprocal-trade/">Learn more</a>.

Check out the latest <a href="https://www.thompsonhine.com/insights/employment-legislation-outlook-december-2025/">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&nbsp;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 – December 2025

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