Twelve TSCA Developments To Expect In 2025

This alert was originally published on December 4, 2024, and has been revised based on recent developments.

With the election of Donald Trump, the implementation of the Toxic Substances Control Act (TSCA) in 2025 will differ significantly from the pre-election expectations. Here are our projections on the likely developments in the coming year.

March 2025 Update

Expect significant changes to the TSCA program under the Trump EPA relatively soon. To date, however, EPA has suggested that it may revise many of the TSCA actions taken by the Biden EPA, while delaying definitive announcements of changes. Exceptions include EPA's cutting employees and announcing that it will reconsider the TSCA risk evaluation framework rule, which will likely affect future, in-progress, and possibly completed risk evaluations.