EPA's 2026 Regulatory Agenda for Manufacturers: 20 Rules, 4 Media, and Why Eight of Nine July Dates Never Happened
EPA's 2026 agenda filtered to the air, RCRA, TSCA and PFAS actions that hit industrial plants: RINs, dockets, projected dates, and what those dates really mean.
EPA published its 2026 regulatory agenda preamble on August 14, 2026 at 91 FR 53054. If you run EHS at an industrial manufacturer, roughly 20 of the agency’s ~130 entries actually land on your plant: NESHAP reconsiderations, a RCRA permitting rewrite, TSCA solvent rules, and four separate PFAS tracks. That is the useful list, and it is below with RINs and dockets.
But start with a number we generated ourselves, because it changes how you should read every date in this document. Of the nine final-rule milestones in our filtered set that EPA projected for July 2026, eight had no Federal Register document as of August 19, 2026. The ninth published in June, before the agenda that listed it as upcoming.
Are EPA’s Unified Agenda Dates Legally Binding Deadlines?
No. EPA states in its own preamble that a date shown as 03/00/2026 “means the agency is predicting the month and year the action will take place but not the day it will occur” (91 FR 53056). These are agency forecasts. They create no obligation, they are not enforceable, and eight of the nine July 2026 final-rule projections we tracked had not published five days after the agenda was issued.
EPA also states there is “no legal significance to the omission of an item from the agenda.” The reverse is equally true: there is no legal significance to its inclusion. Treat every projected date in the tables below as EPA’s projected timing and nothing more.
How we measured the slippage (and how you can repeat it)
This is iSi’s own analysis, not a published study. We looked for one and did not find one: federalregister.gov, reginfo.gov, GAO and the GWU Regulatory Studies Center all describe agencies as routinely missing projected dates, but none of them quantifies a rate. So we measured it.
Method. We took every action in our filtered set carrying a Final Rule milestone of 07/00/2026, then queried the Federal Register API by RIN to check whether any Federal Register document existed as of August 19, 2026. Anyone can reproduce this in about twenty minutes.
Result: eight of nine had not published. The unpublished set: 2070-AK85 (NMP), 2070-AL27 (TSCA risk evaluation procedures), 2070-AL29 (PFAS reporting revision), 2070-AL03 (PFAS TRI additions), 2060-AW77 (Title V applicable requirements), 2060-AW55 (Carbon Pollution Standards repeal), 2060-AW76 (GHGRP reconsideration), and the final-rule leg of 2040-AG49.
The single exception, 2060-AW74 (the Congressional Review Act revocation of the rubber tire NESHAP), had already published on June 22, 2026, before the August 14 agenda listed it as upcoming with a July projection. That is the other failure mode. The agenda is stale on arrival in both directions.
Two structural reasons this edition is worse than usual. It is a combined release covering what would normally have been Fall 2025 and Spring 2026, so its data froze months before publication. And it posted to reginfo.gov on July 3, 2026 but did not reach the Federal Register until August 14, a six-week lag during which several projections expired.
The directional finding you can plan against: in this cycle, deregulatory actions have run ahead of the agenda and regulatory actions have run behind it. AW74 published early. The drinking-water PFAS actions 2040-AG49 and 2040-AG53 both published NPRMs in May against a July projection. The rules that would impose new obligations are the ones sitting.
What Is the EPA 2026 Unified Agenda and When Was It Published?
The agenda preamble published August 14, 2026 at 91 FR 53054-53061 (FR Doc 2026-16608). The full database posted to reginfo.gov on July 3, 2026 under pubId=202510. It is a combined edition covering Fall 2025 and Spring 2026, the first release since the Spring 2025 agenda, which itself did not publish until September 2025.
One structural point most summaries miss, and it will cost you if you rely on the Federal Register notice alone. FR Doc 2026-16608 is not EPA’s agenda. It is EPA’s preamble plus the Regulatory Flexibility Act subset: nine entries, sequence numbers 321 through 329, covering rules with a likely significant economic impact on a substantial number of small entities plus rules selected for section 610 lookback review. EPA says so directly, noting that the comprehensive agenda “is only available through an online database at reginfo.gov.” Read only the Federal Register notice and you see nine items instead of roughly 130.
What Does “Deregulatory” Mean on the Agenda, and Why Should a Plant Care?
It is EPA’s own designation under Executive Order 14192, shown in reginfo’s “EO 14192 Designation” field. EPA tagged 99 actions deregulatory against 31 regulatory this cycle, a 3.2-to-1 ratio (American Action Forum analysis, July 8, 2026). It matters because a rule being relaxed changes your capital plan as much as a new rule does.
For a manufacturer, the realistic 2026-2027 exposure is not a wave of new requirements. It is planning whiplash: capital already committed against 2024 final rules that EPA has now reopened.
The Filtered Agenda: What Actually Lands on an Industrial Plant
Twenty actions, filtered from roughly 130 EPA entries. “Dereg” reflects EPA’s own EO 14192 designation field, not our reading of it. Where the docket column reads “Not yet assigned,” reginfo’s Additional Information field is blank and no Federal Register document exists yet; those dockets will not exist until the NPRM publishes, so do not go looking for them. The date column is EPA’s projected timing, in EPA’s own notation, where 07/00/2026 means “some day in July 2026.”
Air
For the Q2 2026 air-rule detail behind several of these, see our EPA air rule rollback digest.
| RIN | Action | Stage | EPA Projected Date | Docket |
|---|---|---|---|---|
| 2050-AH37 | Risk Management Program, “Common Sense Approach to Chemical Accident Prevention.” Rolls back the 2024 SCCAP rule. Dereg, Economically Significant. NPRM 02/24/2026, 91 FR 8970; comments closed 04/10/2026 | Proposed Rule | Final Rule 09/00/2026 | EPA-HQ-OLEM-2025-0313 |
| 2050-AH47 | RMP under CAA 112(r)(7): RFA section 610 lookback review of the 2017 RMP rule (82 FR 4594). Statutory review deadline 01/13/2027. EPA states this is unrelated to 2050-AH37 | Prerule | Begin Review 07/00/2026; End Review 01/00/2027 | EPA-HQ-OLEM-2025-3225 |
| 2060-AW76 | Reconsideration of the Greenhouse Gas Reporting Program. Removes GHGRP obligations for most of 47 sectors and 8,000+ facilities. Dereg. NPRM 09/16/2025, 90 FR 44591 | Final Rule | Final Rule 07/00/2026 | EPA-HQ-OAR-2025-0186 |
| 2060-AW89 | NESHAP: Integrated Iron and Steel Manufacturing, technology review reconsideration (40 CFR 63 subpart FFFFF). Reopens the 04/03/2024 final rule, 89 FR 23294. Dereg | Proposed Rule | NPRM 07/00/2026; Final 03/00/2027 | EPA-HQ-OAR-2002-0083 |
| 2060-AW80 | NESHAP reconsideration for Coke Ovens: pushing, quenching, battery stacks and coke oven batteries (subparts CCCCC, L). Reopens the 07/05/2024 final rule, 89 FR 55684. Dereg | Proposed Rule | NPRM 07/00/2026; Final 10/00/2027 | EPA-HQ-OAR-2002-0085; EPA-HQ-OAR-2003-0051 |
| 2060-AW91 | NESHAP for Major Source Industrial, Commercial and Institutional Boilers and Process Heaters: amendments to new source dates, responding to the D.C. Circuit vacatur in U.S. Sugar Corp. v. EPA, 113 F.4th 984 (D.C. Cir. 2024). Dereg | Proposed Rule | NPRM 07/00/2026; Final 03/00/2027 | Not yet assigned |
| 2060-AW84 | Revision to “Begin Actual Construction” in New Source Review preconstruction permitting. Dereg. Agenda text cites data center and AI infrastructure buildout as a driver | Proposed Rule | NPRM 07/00/2026; Final TBD | Not yet assigned |
| 2060-AW77 | Scope of “Applicable Requirements” under state and federal Title V operating permit programs. The underlying 01/09/2024 proposal at 89 FR 1150 carried RIN 2060-AV61 | Final Rule | Final Rule 07/00/2026 | EPA-HQ-OAR-2023-0401 |
Same pattern, not broken out: 2060-AW53 (Lime Manufacturing RTR reconsideration, Proposed, 07/00/2026, Economically Significant), 2060-AW87 (SOCMI), 2060-AW95 (EAF and AOD steelmaking NSPS), 2060-AW67 (taconite), 2060-AW79 (ethylene oxide sterilizers), 2060-AW70 (primary copper smelting), 2060-AW66 (gasoline distribution), 2060-AV00 (Portland Cement NESHAP amendments, NPRM 11/00/2026), 2060-AW31 (brick, structural clay and clay ceramics section 610 review, End Review 08/00/2026, docket EPA-HQ-OAR-2024-0404).
RCRA
The withdrawn corrective action rule in the last row is covered in depth in our Q2 2026 RCRA corrective action analysis.
| RIN | Action | Stage | EPA Projected Date | Docket |
|---|---|---|---|---|
| 2050-AH30 | Updates to the RCRA Hazardous Waste Regulations and Related Technical Corrections (Permitting Updates Rule). Subtitle C generator, transporter and TSDF amendments; solicits input on permitting reform. Dereg. Listed sectors include NAICS 331-339 | Proposed Rule | NPRM 07/00/2026; Final 07/00/2027 | EPA-HQ-OLEM-2024-0124 |
| 2050-AH35 | e-Manifest Paper Manifest Sunset Rule. NPRM 03/05/2026, 91 FR 10862; comments closed 04/06/2026. Tagged Dereg, but operationally it mandates electronic manifests by sunsetting paper | Proposed Rule | Final Rule 01/00/2027 | EPA-HQ-OLEM-2025-3456 |
| 2050-AH44 | Facilitating Scrap Tire Pile Cleanups. Designates scrap tires burned in cement kilns as non-waste fuel under the NHSM rule, 40 CFR 241. Dereg. NPRM 03/23/2026, 91 FR 13804; comments closed 05/22/2026 | Proposed Rule | Final Rule 10/00/2028 | EPA-HQ-OLEM-2025-1609 |
| 2050-AH39 | Coal Combustion Residuals: legacy impoundments and CCR management units amendments. Dereg, Economically Significant. NPRM 04/13/2026, 91 FR 18968; comments extended to 06/29/2026 | Proposed Rule | Final Rule 09/00/2026 | EPA-HQ-OLEM-2020-0107 |
| 2050-AH27 | Definition of Hazardous Waste Applicable to Corrective Action for Releases From SWMUs. WITHDRAWN. The 02/08/2024 proposal (89 FR 8598) was withdrawn 05/08/2026 at 91 FR 25266 | Completed (Withdrawn) | Withdrawal effective 05/08/2026 | EPA-HQ-OLEM-2023-0085 |
Also on the agenda: 2050-AH07 (Federal CCR Permit Program, Final, 07/00/2026), 2050-AH32 (universal waste standards for solar panels and lithium batteries), 2050-AH21 (LDR elemental mercury variance), 2050-AH24 (open burning and open detonation of waste explosives), 2050-AH40 (EPCRA Tier II conforming amendments to the 2024 OSHA HazCom rule), 2050-AH42 (CCR alternative closure deadline).
TSCA
| RIN | Action | Stage | EPA Projected Date | Docket |
|---|---|---|---|---|
| 2070-AK85 | N-Methylpyrrolidone (NMP), section 6(a) risk management. Would prohibit several occupational conditions of use and require a Workplace Chemical Protection Program or prescriptive controls, plus recordkeeping, labeling and downstream notification. Regulatory, Economically Significant. NPRM 06/14/2024, 89 FR 51134 | Final Rule | Final Rule 07/00/2026 | EPA-HQ-OPPT-2020-0744 |
| 2070-AK73 | 1-Bromopropane (1-BP), section 6(a) risk management for vapor and aerosol degreasing, adhesives and sealants, insulation. Regulatory. NPRM 08/08/2024, 89 FR 65066 | Final Rule | Final Rule 08/00/2026 | EPA-HQ-OPPT-2020-0471 |
| 2070-AL37 | Multiple Compliance Date Extensions Under TSCA. Pushes back compliance dates across the methylene chloride, TCE, PCE and carbon tetrachloride section 6(a) rules. Dereg | Proposed Rule | NPRM 07/00/2026; Final 10/00/2026 | EPA-HQ-OPPT-2020-0465, -0642, -0720, -0592 |
| 2070-AL41 | Trichloroethylene (TCE): amendments to the December 2024 section 6(a) rule. Parallel entries exist for PCE (2070-AL39) and carbon tetrachloride (2070-AL42) | Proposed Rule | NPRM 07/00/2026; Final 07/00/2027 | EPA-HQ-OPPT-2020-0642 |
| 2070-AL27 | Procedures for Chemical Risk Evaluation Under TSCA. Rewrites the section 6(b) framework feeding every future 6(a) risk management rule. Dereg. NPRM 09/23/2025, 90 FR 45690 | Final Rule | Final Rule 07/00/2026 | EPA-HQ-OPPT-2025-0260 |
Also on the agenda: 2070-AL22 (formaldehyde section 6(a), NPRM 08/00/2026), 2070-AL38 (formaldehyde emission standards for composite wood products, section 610 review, Begin 07/00/2026, docket EPA-HQ-OPPT-2025-2433), 2070-AL25 (DIDP), 2070-AL26 (DINP), 2070-AL21 (asbestos Part 2, legacy uses, NPRM 02/00/2027), 2070-AK88 (1,4-dioxane, Long-Term, next step “To Be Determined”), 2070-AL43 (extension for TSCA section 8(d) health and safety data reporting).
Two absences worth noting, because both get assumed the other way. There is no asbestos Part 1 (chrysotile) reconsideration RIN; EPA’s own 2070-AL21 abstract states it “completed its Part 1 risk evaluation and rulemaking activities for Chrysotile Asbestos.” And there is no TSCA section 8(a) Chemical Data Reporting rulemaking anywhere in the 2026 edition. The only section 8 action is the 8(d) extension.
PFAS
| RIN | Action | Stage | EPA Projected Date | Docket |
|---|---|---|---|---|
| 2070-AL29 | PFAS Data Reporting and Recordkeeping Under TSCA: revision to regulation. The scope revision to the section 8(a)(7) reporting rule. Dereg, Economically Significant. NPRM 11/13/2025, 90 FR 50923. Its effective date is the trigger that starts the reporting window | Final Rule | Final Rule 07/00/2026 | EPA-HQ-OPPT-2020-0549 |
| 2050-AH26 | Listing of Specific PFAS as Hazardous Constituents (RCRA Appendix VIII). Regulatory. NPRM 02/08/2024, 89 FR 8606. Appendix VIII listing is the gateway to corrective action obligations at permitted TSDFs | Final Rule | Final Rule 01/00/2027 | EPA-HQ-OLEM-2023-0278 |
| 2070-AL03 | Addition of Certain PFAS to the Toxics Release Inventory. Regulatory. NPRM 10/08/2024, 89 FR 81776 | Final Rule | Final Rule 07/00/2026 | EPA-HQ-OPPT-2023-0538 |
| 2040-AG49 | Extending the compliance deadline for the PFOA and PFOS maximum contaminant levels. Dereg. NPRM published 05/20/2026. Companion 2040-AG53 would rescind regulatory determinations for PFHxS, PFNA, HFPO-DA/GenX and the mixture, Final projected 09/00/2026 | Proposed Rule | NPRM 07/00/2026; Final 07/00/2026 | Not listed |
Also on the agenda: 2070-AL44 (PFAS reporting deadline extension, completed, final rule 04/13/2026 at 91 FR 18786), 2040-AG10 (CWA effluent guidelines for PFAS manufacturers, OCPSF category, NPRM 07/00/2026), 2040-AG24 (metal finishing ELG revisions addressing PFAS in chromium electroplating wastewater, NPRM 02/00/2027), 2040-AG40 (landfills ELG, Long-Term), 2050-AH25 (Addressing PFAS in the Environment, Long-Term, “To Be Determined”).
Which EPA NESHAP Rules Are Being Reconsidered in 2026?
At least nine manufacturing source categories: integrated iron and steel (2060-AW89), coke ovens (2060-AW80), lime manufacturing (2060-AW53), industrial boilers (2060-AW91), SOCMI (2060-AW87), EAF steelmaking (2060-AW95), taconite (2060-AW67), ethylene oxide sterilizers (2060-AW79) and primary copper smelting (2060-AW70). All nine sit at Proposed stage, and all nine reopen 2024 final rules.
If your Title V permit cites a 40 CFR part 63 subpart on that list, and you built a compliance plan against a 2024-vintage rule, this is the group to watch. It is also the group that produces the single most expensive mistake on this agenda, which is the next question.
Does a Proposed Reconsideration Suspend My NESHAP Compliance Date?
No. A proposed rule has no legal effect on a final rule already codified in the CFR. The 2024 NESHAP compliance dates for integrated iron and steel (89 FR 23294), coke ovens (89 FR 55684), lime manufacturing and ethylene oxide sterilization remain binding and enforceable unless and until a reconsideration is finalized or a court stays the rule. A reopened proposal is not a reprieve.
This is worth being blunt about. The facilities that get hurt in a deregulatory cycle are almost never the ones that acted too late on a proposal. They are the ones that eased off a final rule because they saw a reconsideration on the agenda. Proposals get withdrawn: RIN 2050-AH27 is the proof, withdrawn in May 2026 after two years of sitting at Proposed stage.
Is the TSCA PFAS Reporting Deadline Still October 13, 2026?
No, and any source still saying so is stale. FR Doc 2026-07062, published April 13, 2026 at 91 FR 18786, superseded the October 13, 2026 start and the April 13, 2027 small-importer date. The window now begins January 31, 2027, or 60 days after the effective date of the 2070-AL29 final rule, whichever comes earlier.
EPA has not set an end date. The rule text is explicit: it “addresses only the date on which the data submission period begins and does not address the end of the submission period.” Prior EPA statements described a six-month window, twelve months for small article importers, but the closing date is not fixed in a published rule today.
The timing is in flux. The obligation is not. The reporting rule is final and codified at 40 CFR part 705. The look-back runs from 2011 through 2022, there is no de minimis and no volume threshold, and importing an article containing PFAS is enough to trigger it. Fluoropolymer-lined equipment, PTFE gaskets and seals, fluorinated coatings, fire-fighting foam, fluorinated HDPE containers: all in scope.
Which is why the data collection is the work, and it starts now rather than when the window opens. You are reconstructing purchasing records that are eleven to fifteen years old. Firms that wait for the trigger will not finish in six months.
Is the CERCLA PFOA and PFOS Designation Being Repealed?
No. RIN 2050-AH09 does not appear anywhere in the 2026 agenda: not in active actions, not in long-term actions, not in completed actions. No rescission or reconsideration RIN exists. The May 2024 final designation (89 FR 39124, effective July 8, 2024) remains in force today.
Absence from the agenda is not repeal, and this is the assumption to correct hardest. EPA says plainly that there is “no legal significance to the omission of an item from the agenda.” The only related live entry is 2050-AH46, a CERCLA section 102(a) framework rule governing how EPA weighs costs in future designations, and it is a Long-Term Action with an NPRM projected for 10/00/2027 and a final rule for 02/00/2030.
Practical read: PFOA and PFOS are CERCLA hazardous substances now, the Phase I ESA and property transaction implications are live now, and nothing on this agenda changes that.
Did EPA Withdraw the RCRA Corrective Action Hazardous Waste Definition Rule?
Yes. The February 8, 2024 proposal (89 FR 8598, RIN 2050-AH27) was formally withdrawn effective May 8, 2026 at 91 FR 25266. EPA concluded that existing RCRA section 3005(c)(3) omnibus permitting authority already suffices, and that the rule “could have complicated, rather than contributed to, efficient implementation of corrective action.”
Two years on the agenda, then nothing. Keep that in view when you are tempted to budget against a proposal.
Did EPA Civil Penalties Increase in 2026?
No. The 2026 civil monetary penalty inflation adjustment was cancelled. OMB Memorandum M-26-11, issued April 17, 2026, cancelled it because the fall 2025 lapse in appropriations prevented BLS from producing October 2025 CPI-U data, and the statute allows no alternative calculation. 2025 penalty levels carry forward unchanged. This is the first cancellation of the annual adjustment since the 2015 Improvements Act took effect.
A note on sourcing, because this one is being reported wrong in circulated alerts. The memorandum itself is published as a PDF on whitehouse.gov, and it is also quoted by number, name and date in the Federal Register in the Notice on Penalty Inflation Adjustments for Civil Monetary Penalties, 91 FR 33284 (June 3, 2026). We verified it a second way as well: a Federal Register API query returns zero EPA civil penalty adjustment rules published in 2026, and 40 CFR part 19 remains as last amended at 90 FR 1377, January 8, 2025.
Do not oversell the relief either. A freeze is not a reduction, and the adjustment resumes whenever October CPI-U data is available again.
What Is the Maximum EPA Fine Per Day in 2026?
$124,426 per day, per violation under both Clean Air Act section 113(b) and RCRA section 3008(a)(3), per 40 CFR 19.4, Table 1, third column. These figures apply to violations assessed on or after January 8, 2025 and are still operative because the 2026 adjustment was cancelled.
| Statute | Citation | Per day, per violation |
|---|---|---|
| Clean Air Act 113(b) | 42 U.S.C. 7413(b) | $124,426 |
| Clean Air Act 113(d)(1), administrative | 42 U.S.C. 7413(d)(1) | $59,114 (with a $472,901 cap) |
| RCRA 3008(a)(3) | 42 U.S.C. 6928(a)(3) | $124,426 |
| RCRA 3008(g) | 42 U.S.C. 6928(g) | $93,058 |
| RCRA 3008(c) and (h)(2) | 42 U.S.C. 6928(c), (h)(2) | $74,943 |
| EPCRA 325(a) | 42 U.S.C. 11045(a) | $71,545 |
| CERCLA 109(a)(1) | 42 U.S.C. 9609(a)(1) | $71,545 |
| Clean Water Act 309(d) | 33 U.S.C. 1319(d) | $68,445 |
| TSCA 16(a)(1) | 15 U.S.C. 2615(a)(1) | $49,772 |
Three things practitioners get wrong here. Penalties run per day and per violation, so a recordkeeping gap across twelve manifests over ninety days is not one violation. The TSCA figure is the one that attaches to a PFAS section 8(a)(7) reporting failure, because a missed reporting obligation is a section 15 prohibited act. And EPA’s penalty policies apply gravity and economic-benefit components against these statutory maximums, so assessed penalties usually land well below the ceiling. The ceiling is what sets settlement leverage.
Which EPA Rules Actually Became Final in 2026?
Twelve significant EPA final rules published between January 1 and August 19, 2026. Among them: the rescission of the greenhouse gas endangerment finding (February 18), two MATS repeal actions (February 24 and April 16), the hazardous waste combustors residual risk and technology review (June 3), the Congressional Review Act revocation of the rubber tire manufacturing NESHAP (June 22), and the PCE and carbon tetrachloride compliance date rule (July 28).
Notice what that list has in common with the agenda: not much. Courts and Congress moved rules that never appeared as planned agenda items. The Boiler MACT new-source-date rulemaking (2060-AW91) exists because the D.C. Circuit vacated part of the rule in U.S. Sugar Corp. v. EPA, 113 F.4th 984 (D.C. Cir. 2024). RIN 2060-AW74 exists only to strip already-void text out of the CFR after a CRA resolution. The agenda is one input among several.
When Do Kansas, Missouri, Oklahoma and Nebraska Have to Adopt New Federal EPA Rules?
For RCRA, 40 CFR 271.21(e)(2)(ii) gives an authorized state until July 1 of each year to adopt federal changes from the twelve months preceding the previous July 1, a structural lag of up to roughly 23 months. States needing a statutory amendment get an additional year under 271.21(e)(2)(v), and a Regional Administrator may grant up to six more months under 271.21(e)(3). Worst case: about 41 months.
Work it on a real example. If EPA finalizes the RCRA Permitting Updates Rule (2050-AH30) in July 2027 as projected, that change falls in the July 1, 2027 to June 30, 2028 window, and the state adoption deadline is July 1, 2029.
Kansas (KDHE), Missouri DNR, Nebraska NDEE, Oklahoma DEQ and Texas TCEQ all run authorized RCRA base programs under RCRA section 3006. Once a state is authorized, the state’s rules, not EPA’s, are the enforceable requirements for authorized portions of the program.
This cuts both ways, and in a deregulatory cycle the second direction is the more likely failure:
- On new requirements: a federal rule finalized in 2027 may not bind your Kansas plant until 2029 or later. Do not budget a capital project against the federal date.
- On relief: if EPA relaxes a requirement, the older and stricter state rule stays enforceable until the state adopts the change. A facility that acts on federal deregulatory relief before its state adopts it is out of compliance with state law.
- State-only stringency: RCRA section 3009 expressly permits states to be more stringent than the federal floor, and those provisions are untouched by federal rollbacks.
Air works differently again. NESHAP and NSPS standards apply directly as federal requirements and are typically written into Title V permits, so the lag is shorter, but permit reopening becomes the gating step and runs on its own state timeline. TSCA section 6(a) rules apply directly with no state intermediary, which is why the solvent rules reach the shop floor fastest.
One caveat we will not paper over: the 40 CFR 271.21(e) mechanism above is verified against the current eCFR, but we did not individually confirm which federal checkpoint each of those five state programs is currently authorized through. Confirm that with your state agency before you rely on it.
The Honest Answer for Most Plants: Track It, Do Not Act Yet
For the large majority of the twenty actions above, the correct action today is to set a docket alert and go back to work.
Track only, spend nothing: every Air row at Proposed Rule stage, every reconsideration RIN, every prerule section 610 review. None of them changes an obligation today. Rebuilding a compliance plan around a proposed rule is a common and expensive error. Concretely, “tracking” means setting a docket alert on regulations.gov for the dockets in the tables and re-checking the entry at the next agenda edition. That is the entire job.
Plan for both outcomes on exactly one item: the GHGRP reconsideration (2060-AW76). If it is finalized as proposed, most reporters across 47 sectors drop out. If it is not finalized, or is vacated on review, 40 CFR part 98 obligations continue. Keep collecting part 98 data. Decide about reporting when the final rule publishes, not before.
Act now on the short list:
- TSCA section 8(a)(7) PFAS data collection. Final rule, codified, 2011-2022 look-back, no de minimis. Start with purchasing records and supplier outreach.
- PFOA and PFOS CERCLA obligations. In force, not scheduled for rescission, with live implications for property transactions and Phase I ESAs.
- 2024 NESHAP compliance dates. Still binding across all nine reopened categories.
- The methylene chloride, TCE, PCE and carbon tetrachloride section 6(a) rules. Final, with extended compliance dates that govern. An extension is not a repeal.
And be skeptical of presence on the agenda as evidence of momentum. 1,4-dioxane (2070-AK88) is a Long-Term Action with a next step of “To Be Determined.” The halogenated solvent cleaners NESHAP (2060-AW44), which would set MACT for 1-bromopropane, carries an NPRM date of 02/00/2029 and a final rule date of 07/00/2030, on a rulemaking responding to petitions filed after a 2007 rule.
Comment Windows Actually Open Right Now
These are real deadlines with published dates, unlike everything in the projected-date columns above. For the fuller deadline picture across both agencies, see our 2026 EPA and OSHA compliance deadline roundup, and for the OSHA-side rulemaking counterpart to this post, see OSHA health standards rulemaking in 2026.
| Date | What closes | Source |
|---|---|---|
| September 2, 2026 | Comments on the proposed 2027 NPDES Construction General Permit for stormwater discharges from construction activities (docket EPA-HQ-OW-2025-0760) | FR Doc 2026-15656 |
| September 28, 2026 | Comments on ICR renewals for RCRA generator standards applicable to laboratories owned by eligible academic entities (EPA-HQ-OLEM-2018-0692) and Land Disposal Restrictions (EPA-HQ-OLEM-2018-0198) | FR Doc 2026-15393, FR Doc 2026-15379 |
| October 9, 2026 | Comments on TSCA draft risk evaluations for o-dichlorobenzene and p-dichlorobenzene (EPA-HQ-OPPT-2018-0444, -0446) | FR Doc 2026-16263 |
| October 19, 2026 | Comments on the TSCA draft risk evaluation for ethylene dibromide (EPA-HQ-OPPT-2018-0488) | FR Doc 2026-16919 |
| Roughly October 13, 2026 (60 days from August 14 publication; no calendar date was set in the Federal Register metadata, so confirm on the docket) | Comments on EPA’s three newly initiated section 610 lookback reviews: Risk Management Program (EPA-HQ-OLEM-2025-3225), formaldehyde emission standards for composite wood products (EPA-HQ-OPPT-2025-2433), and Oil and Natural Gas Sector NSPS (EPA-HQ-OAR-2025-3160) | 91 FR 53054 |
Commenting on a draft risk evaluation is far cheaper than commenting on the section 6(a) rule it eventually produces. That is the step most manufacturers skip.
A 30-Minute Self-Check
- Pull your Title V permit and list every 40 CFR part 63 subpart cited. Cross-reference against the reconsideration RINs above.
- Pull your RCRA generator status notification (EPA Form 8700-12) and confirm LQG, SQG or VSQG.
- Confirm whether you file 40 CFR part 98 greenhouse gas reports.
- Confirm whether you hold a 40 CFR part 68 Risk Management Plan.
- Search your SDS inventory for CAS 872-50-4 (NMP), 106-94-5 (1-BP), 79-01-6 (TCE), 127-18-4 (PCE), 75-09-2 (methylene chloride) and 56-23-5 (carbon tetrachloride).
- Ask purchasing for imported articles since 2011 and whether any supplier has ever provided a PFAS declaration. This is the most commonly missed obligation on the entire list.
Where iSi Fits
Most facilities do not need help acting on this agenda. They need help deciding what not to act on, and then not missing the two or three items that are real. That is what a standing compliance program does: someone reads the Federal Register weekly, keeps the docket alerts, knows which of your part 63 subparts got reopened, and tells you when a projection turns into a published rule.
iSi’s compliance program management covers exactly that, along with the two items on this agenda that carry real near-term work: TSCA section 8(a)(7) PFAS import reconstruction back to 2011, and Title V permit review against the reopened NESHAP categories. If you want a second set of eyes on which of these twenty RINs actually touch your permits, start with the Compliance Gap Checker or call us and we will walk your permit against the list.
Related Reading
- EPA Q2 2026 deregulatory cycle: RCRA corrective action and manufacturer compliance
- EPA air rule rollback: the 2026 deregulatory cycle
- 2026 EPA and OSHA compliance deadlines
- OSHA health standards rulemaking in 2026
This post is the forward-looking tracker across all four media. Those four are the deep dives.
Sources
Primary (.gov)
- EPA 2026 Unified Agenda of Regulatory and Deregulatory Actions, 91 FR 53054-53061, FR Doc 2026-16608, August 14, 2026: https://www.govinfo.gov/content/pkg/FR-2026-08-14/html/2026-16608.htm (verified 2026-08-19)
- Same document on federalregister.gov: https://www.federalregister.gov/documents/2026/08/14/2026-16608/2026-unified-agenda-of-regulatory-and-deregulatory-actions (verified 2026-08-19)
- Unified Agenda database, pubId 202510, reginfo.gov: https://www.reginfo.gov/public/do/eAgendaMain (verified 2026-08-19). Per-RIN entries follow the pattern
https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=<RIN> - 40 CFR 19.4, statutory civil monetary penalties as adjusted for inflation: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-A/part-19/section-19.4 (verified 2026-08-19)
- 40 CFR 271.21, procedures for revision of state programs: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-A/part-271/section-271.21 (verified 2026-08-19)
- Notice on Penalty Inflation Adjustments for Civil Monetary Penalties, 91 FR 33284, June 3, 2026, which quotes OMB M-26-11 by number, name and date: https://www.federalregister.gov/documents/2026/06/03/2026-11050/notice-on-penalty-inflation-adjustments-for-civil-monetary-penalties (verified 2026-08-19)
- Modification to the Start of the Submission Period for PFAS Reporting Under TSCA 8(a)(7), 91 FR 18786, FR Doc 2026-07062, April 13, 2026: https://www.federalregister.gov/documents/2026/04/13/2026-07062/modification-to-the-start-of-the-submission-period-for-perfluoroalkyl-and-polyfluoroalkyl-substances (verified 2026-08-19)
- Definition of Hazardous Waste Applicable to Corrective Action for Releases From SWMUs; Withdrawal, 91 FR 25266, FR Doc 2026-09179, May 8, 2026: https://www.federalregister.gov/documents/2026/05/08/2026-09179/definition-of-hazardous-waste-applicable-to-corrective-action-for-releases-from-solid-waste (verified 2026-08-19)
- Accidental Release Prevention Requirements: Risk Management Programs; Common Sense Approach (NPRM), 91 FR 8970, February 24, 2026: https://www.federalregister.gov/documents/2026/02/24/2026-03633/accidental-release-prevention-requirements-risk-management-programs-under-the-clean-air-act-common (verified 2026-08-19)
- Reconsideration of the Greenhouse Gas Reporting Program (NPRM), 90 FR 44591, September 16, 2025: https://www.federalregister.gov/documents/2025/09/16/2025-17923/reconsideration-of-the-greenhouse-gas-reporting-program (verified 2026-08-19)
- Paper Manifest Sunset Rule (NPRM), 91 FR 10862, March 5, 2026: https://www.federalregister.gov/documents/2026/03/05/2026-04366/paper-manifest-sunset-rule-modification-of-the-hazardous-waste-manifest-regulations (verified 2026-08-19)
- Protecting Public Health and Unleashing American Energy by Facilitating Scrap Tire Pile Cleanups (NPRM), 91 FR 13804, March 23, 2026: https://www.federalregister.gov/documents/2026/03/23/2026-05586/protecting-public-health-and-unleashing-american-energy-by-facilitating-scrap-tire-pile-cleanups (verified 2026-08-19)
- EPA Regulatory Agendas and Regulatory Plans: https://www.epa.gov/laws-regulations/regulatory-agendas-and-regulatory-plans (verified 2026-08-19)
- EPA Regulatory Flexibility Act section 610 reviews: https://www.epa.gov/reg-flex/regulatory-flexibility-act-section-610-reviews (verified 2026-08-19)
- Federal Register API, used for our slippage measurement and the open-comment sweep: https://www.federalregister.gov/developers/documentation/api/v1 (verified 2026-08-19)
Secondary, used only where labeled
- American Action Forum, “The 2026 Unified Agenda: Checking In on the Trump 2.0 Deregulatory Agenda,” July 8, 2026: https://www.americanactionforum.org/insight/the-2026-unified-agenda-checking-in-on-the-trump-2-0-deregulatory-agenda/ (verified 2026-08-19). Source for the 3,326 total actions figure, the EPA 99/31 designation split, and the July 3, 2026 posting date.
Notes on sourcing limits
- The 8-of-9 slippage figure is iSi’s own measurement against the Federal Register API as of August 19, 2026, not a published study. We searched for a quantitative study of historical Unified Agenda date slippage and found none.
- Dockets for RINs 2060-AW84, 2060-AW91, 2060-AW53, 2060-AV00 and 2060-AW74 are not yet assigned. Reginfo’s Additional Information field is blank and no Federal Register document exists yet.
- OMB Memorandum M-26-11 (April 17, 2026) is available at https://www.whitehouse.gov/wp-content/uploads/2026/04/M-26-11-Cancellation-of-Penalty-Inflation-Adjustments-for-2026-Regarding-the-Federal-Civil-Penalties-Inflation-Adjustment-Act-Improvements-Act-of-2015.pdf (verified 2026-09-09). It is also quoted by number, name and date in 91 FR 33284.
- The current RCRA authorization revision checkpoint for KDHE, Missouri DNR, Oklahoma DEQ, Nebraska NDEE and TCEQ was not individually verified. The 40 CFR 271.21(e) mechanism is verified; per-state status should be confirmed with the agency.