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Summary of Regulatory Dynamics | US Update on Lead, Dichloromethane, and PFAS Control Requirements
Time：
2024-06-25
US Update on Lead, Dichloromethane, and PFAS Control Requirements
01. Vermont Revised Commodity Law for PFAS and Other Compounds
|
Target group |
American manufacturers and distributors; US importers and their upstream suppliers |
|
Involving products |
consumer goods |
|
Key industries involved |
Cooking utensils, youth products, upholstered furniture, food packaging |
|
Execution date |
January 1, 2026 |
Primary coverage
The Governor of Vermont signed and passed the SB 25 Act on May 30, 2024, which controls perfluorinated and multi fluorinated compounds (PFAS), bisphenols, and phthalates.
02. The United States has finalized a TSCA rule to ban dichloromethane
|
Target group |
US manufacturers, distributors, retailers |
|
Involving products |
Products involving dichloromethane |
|
Key industries involved |
All fields applied to consumers (89 FR 39254) |
|
Execution date |
Starting from February 3, 2025 |
Primary coverage
On April 30, 2024, the US Environmental Protection Agency (EPA) passed a rule for multi-purpose dichloromethane in accordance with the risk management provisions of the Toxic Substances Control Act (TSCA). This rule will take effect on July 8, 2024, 60 days after its publication in the Federal Register.
This rule prohibits the use of dichloromethane in the following consumer uses:
It is prohibited to distribute dichloromethane and products containing dichloromethane to retailers for any purpose after February 3, 2025.
Retailers are prohibited from distributing dichloromethane and products containing dichloromethane for any purpose after May 5, 2025.
Production (including import) of dichloromethane is prohibited after May 5, 2025.
Processing of dichloromethane and products containing dichloromethane is prohibited after August 1, 2025.
Distribution of dichloromethane and products containing dichloromethane is prohibited after January 28, 2026.
Prohibit the use of dichloromethane and products containing dichloromethane in industry or commerce after April 28, 2026.
*Provide a limited exemption for NASA and its contractors for a period of 10 years; Provide a limited exemption of 5 years for the industrial or commercial use of paint and coating removal products, as well as adhesives and sealants used for structural and safety critical non structural purposes in aircraft, spacecraft, and turbine applications, when renovating wooden furniture, decorations, and building fixtures with artistic, cultural, or historical value.
This ban does not apply to dichloromethane products with concentrations below 0.1% (w/w), with a limit of 0.1% (1000 mg/kg).
03. Connecticut Releases Regulatory Act for PFAS in Certain Consumer Products
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Target group |
American manufacturers and distributors; US importers and their upstream suppliers |
|
Involving products |
consumer goods |
|
Key industries involved |
Cooking utensils, youth products, upholstered furniture, food packaging, etc |
|
Execution date |
January 1, 2026 |
Primary coverage
The Governor of Connecticut signed SB 292 into law on June 5, 2024 (Public Act 24-59) to regulate PFAS in various consumer goods. The bill will come into effect on October 1, 2024,
04. Washington issues new bill HB1551 to restrict lead in cookware
|
Target group |
American manufacturers, distributors, retailers, wholesalers; US importers and their upstream suppliers |
|
Involving products |
cooker |
|
Execution date |
January 1, 2026 |
Primary coverage
Washington State issued Act HB1551 on March 28, 2024, which limits the lead content in cookware and cookware components.
According to the bill, starting from January 1, 2026, any manufacturer or retailer is prohibited from producing, selling, or distributing cookware or cookware components containing lead and its lead compounds exceeding 5ppm. Violators will be subject to certain penalties.
05. Colorado Revises PFAS Restrictions in Consumer Goods
|
Target group |
American manufacturers and distributors; US importers and their upstream suppliers |
|
Involving products |
consumer goods |
|
Execution date |
Starting from January 1st, 2025 |
Primary coverage
The Governor of Colorado approved Act SB 24-081 on May 1, 2024, amending the PFAS restriction requirements for consumer goods. Products containing intentionally added PFAS substances shall not be sold, offered for sale, distributed, or used in Colorado after the relevant effective date.
In addition, the disclosure requirement on the product label for cookware containing intentionally added PFAS substances on the product handle or any product surface in contact with food or beverages will be abolished on January 1, 2026.
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