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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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Evolving Policy, Regulatory, Health &amp; Safety Issues Addressed at ASC’s Convention in April

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The policy and regulatory landscape is evolving rapidly in the U.S. as the new administration enacts their agenda, new state &amp; local regulations take hold, health &amp; safety technologies evolve, and Europe enacts new regulations. Attend ASC’s Convention in Jacksonville, Florida in April to learn about these critical and ever-changing policies including:

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Election 2024: Public Policy Implications for the U.S. Adhesive and Sealant Industry

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State and Federal Chemical Regulation Impacting Adhesives and Sealants

Recent Advances in Health and Safety Improvements of Cyanoacrylate Adhesives

Low Odor and Label-friendly Methacrylates for Reactive Adhesives Application

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Learn more about the expo <a href="https://www.ascouncil.org/events/2025-annual-convention-and-expo">here</a>.

Federal Court Blocks Key Aspects of Executive Orders Targeting DEI Programs

On February 21, the U.S. District Court for the District of Maryland issued a nationwide preliminary injunction against three key provisions of two executive orders issued by President Trump that aim to terminate, restrict, and deter diversity, equity, and inclusion (DEI) programs in the federal government and the private sector. The challenged executive orders are Executive Order 14151, “Ending Radical and Wasteful Government DEI Programs and Preferencing,” and Executive Order 14173, “Ending Illegal Discrimination and Restoring Merit-Based Opportunity.” <a href="https://www.thompsonhine.com/insights/federal-court-blocks-key-aspects-of-executive-orders-targeting-dei-programs/">Read more</a>.

U.S. EPA Revives Ohio’s Air Nuisance Rule Despite Regulatory Freeze

On January 20, 2025, the Trump Administration issued a regulatory freeze order requiring the U.S. EPA, along with other federal agencies, to refrain from proposing or issuing new rules until approved by the new administration. The order also directed agencies to consider postponing for sixty (60) days any rule already published in the Federal Register. However, the U.S. EPA’s reinstatement of the Air Nuisance Rule (ANR) into the Ohio State Implementation Plan (SIP) narrowly avoided this scrutiny, as it was finalized just one day after the regulatory freeze order took effect. The reinstatement of the ANR into Ohio’s SIP could have significant implications for Ohio industries, as it authorizes enforcement of the ANR through citizen suits under the Clean Air Act (CAA). <a href="https://www.thompsonhine.com/insights/u-s-epa-revives-ohios-air-nuisance-rule-despite-regulatory-freeze/">Read more</a>.

M&amp;A Surge Expected in 2025: SBA Final Rule Delays Impact of Size Recertifications

On December 17, 2024, the U.S. Small Business Administration (SBA) issued its <a href="https://www.federalregister.gov/documents/2024/12/17/2024-29393/hubzone-program-updates-and-clarifications-and-clarifications-to-other-small-business-programs">final rule</a> to adopt several changes from its proposed rule, “HUBZone Program Updates and Clarifications, and Clarifications to Other Small Business Programs.” The final rule introduces significant changes impacting mergers and acquisitions (M&amp;A) activity in the government contracting sector. Firms involved in acquiring and selling should take note of these recent changes. <a href="https://www.thompsonhine.com/insights/ma-surge-expected-in-2025-sba-final-rule-delays-impact-of-size-recertifications/">Continue reading</a>.

CTA Enforcement Suspended for U.S. Citizens and Domestic Companies, Further Guidance Expected

On Sunday, March 2, 2025, the U.S. Treasury Department issued a <a href="https://home.treasury.gov/news/press-releases/sb0038">press release</a> declaring it suspended the Financial Crimes Enforcement Network (FinCEN) enforcement of the Corporate Transparency Act (CTA) against U.S. citizens and domestic reporting companies. This comes less than two weeks after we <a href="https://www.thompsonhine.com/insights/cta-filing-requirements-reinstated-more-changes-expected/">reported</a> on FinCEN’s February 19, 2025 reinstatement of the reporting requirements under, and enforcement of, the CTA after the United States District Court for the Eastern District of Texas in Smith v. United States Department of the Treasury lifted the last remaining nationwide injunction on the CTA. In that guidance, FinCEN provided a new compliance deadline of March 21, 2025, for most entities, but also indicated it will further reassess its position on the CTA to reduce regulatory burdens on businesses while still prioritizing reporting for entities that posed the highest threat to U.S. national security. <a href="https://www.thompsonhine.com/insights/cta-enforcement-suspended-for-u-s-citizens-and-domestic-companies-further-guidance-expected/">Read more</a>.

USTR Seeks Comment from the Public on Unfair and Non-Reciprocal Foreign Trade Practices

On February 20, 2025, the Office of the United States Trade Representative (USTR) <a href="https://ustr.gov/about-us/policy-offices/press-office/press-releases/2025/february/ustr-seeks-comment-public-unfair-and-non-reciprocal-foreign-trade-practices-0">announced</a> that it is seeking comments from the public to identify and address unfair and non-reciprocal foreign trade practices. This initiative is part of the broader <a href="https://www.whitehouse.gov/presidential-actions/2025/01/america-first-trade-policy/">America First Trade Policy Presidential Memorandum</a> and the <a href="https://www.whitehouse.gov/articles/2025/02/reciprocal-trade-and-tariffs/">Reciprocal Trade and Tariffs Presidential Memorandum</a>.

The USTR is particularly focused on submissions related to the largest trading economies, such as G20 countries, and those with the largest trade deficits in goods with the United States. These countries include Argentina, Australia, Brazil, Canada, China, the European Union, India, Indonesia, Japan, Korea, Malaysia, Mexico, Russia, Saudi Arabia, South Africa, Switzerland, Taiwan, Thailand, Türkiye, the United Kingdom, and Vietnam. <a href="https://www.thompsonhinesmartrade.com/2025/02/ustr-seeks-comment-from-the-public-on-unfair-and-non-reciprocal-foreign-trade-practices/">Learn more</a>.

Reversing the Biden Administration, State Department Recreates the Cuba Restricted List

On February 6, 2025, the State Department <a href="https://www.federalregister.gov/documents/2025/02/06/2025-02282/publishing-the-state-departments-list-of-entities-and-subentities-associated-with-cuba-cuba">republished the “Cuba Restricted List”</a> identifying entities and subentities that are under the control of, or act for or on behalf of, the Cuban military, intelligence, or security services or personnel. The Cuba Restricted List is significant because direct financial transactions with the enumerated entities and subentities are generally prohibited under the Cuban Assets Control Regulations maintained by the Department of the Treasury’s Office of Foreign Assets Control (see 31 C.F.R. Part 515). A “direct financial transaction” refers to (i) “acting as the originator on a transfer of funds whose ultimate beneficiary is an entity or subentity on the [Cuba Restricted List]” or (ii) being “the ultimate beneficiary on a transfer of funds whose originator is an entity or subentity on the Cuba Restricted List, including a transaction by wire transfer, credit card, check, or payment of cash.” The Department of Commerce’s Export Administration Regulations generally deny applications to export or reexport items for use by entities or subentities identified on the Cuba Restricted List as well (see 15 C.F.R. 746.2). <a href="https://www.thompsonhinesmartrade.com/2025/02/reversing-the-biden-administration-state-department-recreates-the-cuba-restricted-list/">Continue reading</a>.

President Trump Announces “Fair and Reciprocal Plan” to Address U.S. Trade Relationships and to Counter Non-Reciprocal Trade with Other Countries

In a February 13, 2025 <a href="https://www.whitehouse.gov/articles/2025/02/reciprocal-trade-and-tariffs/">Memorandum</a>, President Donald Trump instructed the Secretary of Commerce and the U.S. Trade Representative, with input from other agencies, to initiate “all necessary actions to investigate the harm to the United States from any non-reciprocal trade arrangements adopted by any trading partners.” Upon completion of this investigation, the president will receive a report “detailing proposed remedies in pursuit of reciprocal trade relations with each trading partner.” <a href="https://www.thompsonhinesmartrade.com/2025/02/president-trump-announces-fair-and-reciprocal-plan-to-address-u-s-trade-relationships-and-to-counter-non-reciprocal-trade-with-other-countries/">Continue reading</a>.

President Trump Initiates Tariffs on Canada, Mexico and China Under the IEEPA – Tariffs on Mexico and Canada Suspended until March 4 but Tariffs on China Start February 4

[NOTE: This article reflects new developments since its original publication.]

On February 7, President Donald Trump issued an <a href="https://www.whitehouse.gov/presidential-actions/2025/02/amendment-to-duties-addressing-the-synthetic-opioid-supply-chain-in-the-peoples-republic-of-china/">executive order</a> (EO) addressing the additional duties placed on imports into the United States of products of China. The article below stated that use of duty-free de minimis treatment on imports for shipments under $800 was being removed for shipments from China. The president has since rescinded this provision in his previous EO, and duty-free de minimis treatment under 19 U.S.C. 1321 is again available for these imports until the Secretary of Commerce informs President Trump “that adequate systems are in place to fully and expediently process and collect tariff revenue applicable” for such low-value shipments from China, at which time the de minimis duty-free exception will again be removed. <a href="https://www.thompsonhinesmartrade.com/2025/02/president-trump-initiates-tariffs-on-canada-mexico-and-china-under-the-ieepa-tariffs-on-mexico-and-canada-suspended-until-march-1-but-tariffs-on-china-start-february-4/">Continue reading</a>.

Trump Issues America First Investment Policy Memorandum Impacting Foreign Direct Investment into the United States and Outbound Investment to Foreign Adversaries such as China

President Trump issued the <a href="https://www.whitehouse.gov/presidential-actions/2025/02/america-first-investment-policy/">America First Investment Policy Memorandum</a> on February 21, 2025, proclaiming that the United States “is committed to maintaining the strong, open investment environment that benefits our economy and our people, while enhancing our ability to protect the United States from new and evolving threats that can accompany foreign investment.” According to the President, “economic security is national security” and the new Memorandum attempts to strike a balance between promoting foreign direct investment from “allies and partners” while restricting inbound and outbound investment to “foreign adversaries”, defined as the Peoples Republic of China (“PRC”) including the Hong Kong Special Administrative Region and the Macau Special Administrative Region, the Republic of Cuba, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Russian Federation, and the regime of Venezuelan politician Nicolás Maduro. <a href="https://www.thregupdate.com/2025/02/president-trump-issues-america-first-investment-policy-memorandum-impacting-foreign-direct-investment-into-the-united-states-and-outbound-investment-to-foreign-adversaries-such-as-china/">Continue reading</a>.

Ohio Opportunity Zone Tax Credit Program Updates

Ohio’s Opportunity Zone (OZ) Tax Credit program, which awards 10% transferable, non-refundable Ohio tax credits for qualifying equity investments, saw record demand in 2024 that shut out many investors. The allocation of Ohio OZ tax credits for fiscal year 2024 was reduced to $25 million (from $50 million in 2023), and the full year’s allocation was exhausted after just one of the two semi-annual application rounds, leaving investors who made qualifying equity investments between July 1 and December 31, 2024, unable to apply for credits. At this time, the Ohio Department of Development has not indicated that there will be an opportunity to apply for credits for “lost” investments that would otherwise have qualified for the Ohio OZ program. <a href="https://www.thompsonhine.com/insights/ohio-opportunity-zone-tax-credit-program-updates/">Learn more</a>.

Check out the latest <a href="https://www.thompsonhine.com/insights/employment-legislation-outlook-march-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 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 – March 2025

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