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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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September Sustainability Summit Program Released

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The 2025 ASC Adhesive &amp; Sealant Sustainability Summit continues to advance the discussion of sustainability in our industry with a program designed to provide maximum knowledge sharing, networking, and collaboration on sustainability strategies for resiliency amid the changing geopolitical landscape. View the complete program for the September 22-24 summit in Cleveland <a href="https://www.ascouncil.org/events/2025-sustainability-summit#preliminaryprogram">online</a>. Reminder to reserve your hotel rooms by August 29th to receive the group rate of $199 (single/double).

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Federal PFAS Regulation: 2025 Midyear Review

It has been more than six years since EPA issued its first PFAS Action Plan on Valentine’s Day 2019 during the first Trump administration and nearly four years since the Biden administration bolstered the federal government’s response to PFAS with EPA’s PFAS Strategic Roadmap. The second Trump administration has quickly begun to implement an historic deregulatory agenda, including a March 12 EPA announcement, which the agency describes as the <a href="https://www.epa.gov/newsreleases/epa-launches-biggest-deregulatory-action-us-history">“Biggest Deregulatory Action in U.S. History.”</a> Absent from that announcement, however, is any mention of PFAS, raising questions about how EPA would address several ongoing federal PFAS actions including the 2024 Safe Drinking Water Act rule setting maximum contaminant levels (MCLs) for several PFAS, the 2023 TSCA Section 8(a)(7) PFAS Reporting Rule, and the 2024 CERCLA rule designating PFOA and PFAS as “hazardous substances.” <a href="https://www.thompsonhine.com/insights/federal-pfas-regulation-2025-midyear-review/">Continue reading</a>.

Supreme Court to Decide Whether Withdrawal Liability Assumptions May Be Set After an Employer’s Withdrawal

On June 30, 2025, the Supreme Court granted certiorari in M&amp;K Employee Solutions, LLC et al. v. Trustees of the IAM Nat’l Pension Fund to address whether the requirement under ERISA section 4211 that multiemployer pension plans compute withdrawal liability based on the plan’s unfunded vested benefits “as of the end” of the plan year requires the plan to use actuarial assumptions that the actuary adopted at the end of the year, or allows the plan to use actuarial assumptions that the actuary adopted after the end of the year. <a href="https://www.thompsonhine.com/insights/supreme-court-to-decide-whether-withdrawal-liability-assumptions-may-be-set-after-an-employers-withdrawal/">Continue reading</a>.

Update on California’s Climate Disclosure Rules: Key Takeaways from CARB’s May 29 Workshop

On May 29, the California Air Resources Board (CARB) hosted a virtual public workshop addressing the <a href="https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240SB253">Climate Corporate Data Accountability Act (Senate Bill 253)</a>, the <a href="https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240SB261">Climate-Related Financial Risk Act (Senate Bill 261)</a>, and amendments introduced by <a href="https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202320240SB219">Senate Bill 219</a>. During the four-hour session, CARB reviewed emerging themes from its public comment period, shared proposed concepts for regulatory frameworks, and previewed the upcoming rulemaking process with more than 3,000 attendees. Thompson Hine partner <a href="https://www.thompsonhine.com/professionals/tanya-c-nesbitt/">Tanya C. Nesbitt</a>, a member of the firm’s <a href="https://www.thompsonhine.com/services/esg-collaborative/">ESG Collaborative</a>, and <a href="https://www.thompsonhine.com/services/corporate-transactions-securities/">Corporate Transactions &amp; Securities</a> associate <a href="https://www.thompsonhine.com/professionals/matthew-n-leder/">Matthew N. Leder</a> attended the workshop and have provided a summary of the current landscape and insights below. <a href="https://www.thompsonhine.com/insights/update-on-californias-climate-disclosure-rules-key-takeaways-from-carbs-may-29-workshop/">Read more</a>.

FAR 2.0: More Than Just Revisions in FAR Part 10 Release

In our previous <a href="https://www.thompsonhine.com/insights/far-2-0-the-far-revolution-is-here/">client alert</a> on <a href="https://www.whitehouse.gov/presidential-actions/2025/04/restoring-common-sense-to-federal-procurement/">Executive Order 14275 (EO)</a>, Restoring Common Sense to Federal Procurement, we examined class deviations issued for FAR Parts 1 and 34. The FAR Council has continued its reform efforts under the Revolutionary FAR Overhaul (RFO) by releasing revisions to FAR Part 10, which governs market research practices across federal acquisition. In this third client alert in our series, we discuss the changes to FAR Part 10, which aim to streamline and strengthen market research efforts while easing regulatory burdens on agencies and contractors. <a href="https://www.thompsonhine.com/insights/far-2-0-more-than-just-revisions-in-far-part-10-release/">Learn more</a>.

An Unsurprising Sea Change for FCPA Enforcement: Key Features of DOJ’s New FCPA Guidelines

On June 9, 2025, the U.S. Department of Justice (DOJ) issued its much-anticipated guidance on enforcement of the Foreign Corrupt Practices Act (FCPA). The new Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act, released in a memorandum from Deputy Attorney General Todd Blanche, contain few surprises. As expected, the new guidelines align closely with the administration’s top law enforcement priorities: national security, dismantling cartels and transnational criminal organizations, and protecting the global competitiveness of U.S. businesses. These priorities were first outlined in President Trump’s February 10, 2025, Executive Order, <a href="https://www.whitehouse.gov/presidential-actions/2025/02/pausing-foreign-corrupt-practices-act-enforcement-to-further-american-economic-and-national-security/">Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security</a>. <a href="https://www.thompsonhine.com/insights/an-unsurprising-sea-change-for-fcpa-enforcement-key-features-of-dojs-new-fcpa-guidelines/">Read more</a>.

SEC Announces Withdrawal of Proposed Rulemaking Actions

The Securities and Exchange Commission (SEC) is withdrawing a number of notices of proposed rulemaking due to changes in its priorities and the evolving regulatory landscape. While the SEC initially proposed changes in various areas affecting securities and investment practices, it has determined that no final rules will be issued regarding these proposals at this time. This includes proposed regulations that were published between October 2020 and November 2023. The SEC has clarified that should it choose to revisit these regulatory matters, it will introduce new proposals for public comment. <a href="https://www.thompsonhine.com/insights/sec-announces-withdrawal-of-proposed-rulemaking-actions/">Learn more</a>.

CAFC Maintains President Trump’s IEEPA Tariffs Pending Final Decision

On June 10, 2025, the U.S. Court of Appeals for the Federal Circuit (CAFC) issued <a href="https://storage.courtlistener.com/recap/gov.uscourts.cafc.23105/gov.uscourts.cafc.23105.51.0.pdf">a stay</a> keeping both tranches of President Donald Trump’s tariffs implemented under the International Emergency Economic Powers Act of 1977 (IEEPA) (50 U.S.C. § 1701 et seq.) in effect until final adjudication by the appellate court. The per curiam (i.e., unanimous) order extends the <a href="https://storage.courtlistener.com/recap/gov.uscourts.cafc.23106/gov.uscourts.cafc.23106.10.0.pdf">temporary stay</a> previously issued by the CAFC on May 29, 2025, after <a href="https://storage.courtlistener.com/recap/gov.uscourts.cit.17091/gov.uscourts.cit.17091.65.0.pdf">a decision</a> from the U.S. Court of International Trade (CIT) published the day before held that President Trump’s invocation of the IEEPA was unconstitutional and vacated the two tranches. See <a href="https://www.thompsonhinesmartrade.com/2025/05/after-cit-blocks-president-trumps-ieepa-tariffs-cafc-stays-order-pending-review-of-the-cits-judgment-and-injunction/">Update of May 29, 2025</a>. President Trump had invoked the IEEPA to impose so-called “reciprocal” tariffs against nearly every country in the world (see Update of April 10, 2025), and specific tariffs against Canada and Mexico (see Update of March 6, 2025) and China (see <a href="https://www.thompsonhinesmartrade.com/2025/05/china-and-the-united-states-agree-to-temporarily-lower-tariff-rates/">Update of May 12, 2025</a>). <a href="https://www.thompsonhinesmartrade.com/2025/06/cafc-maintains-president-trumps-ieepa-tariffs-pending-final-decision/">Read more</a>.

US and UK Implement General Terms of Trade Deal

On June 16, 2025, the United States and the United Kingdom formally implemented the General Terms for the United States of America and the United Kingdom of Great Britain and Northern Ireland Economic Prosperity Deal (the “General Terms”). In a related <a href="https://www.whitehouse.gov/presidential-actions/2025/06/implementing-the-general-terms-of-the-united-states-of-america-united-kingdom-economic-prosperity-deal/">Executive Order (EO)</a>, President Donald Trump set forth agreements reached with the UK regarding tariffs on imports of (i) automobiles and automobile parts; (ii) civil aircraft; and (iii) future relief on imports of aluminum and steel articles and their derivatives. <a href="https://www.thompsonhinesmartrade.com/2025/06/us-and-uk-implement-general-terms-of-trade-deal/">Continue reading</a>.

Check out the latest <a href="https://www.thompsonhine.com/insights/employment-legislation-outlook-july-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.

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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.

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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 – July 2025

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