November ’26 at-a-glance … environment

November 10, 2026

HFC compliance relief remains unresolved

NAFEM awaits EPA’s response to its request for an extension of the HFC compliance deadline for automatic commercial ice machines and clarification on installation requirements for certain remote condensing units.

ICC tackles customer-operated cooking equipment codes

UL shared that the International Code Council (ICC) formed a task group through its Plumbing, Mechanical and Fuel Gas Code Action and Fire Code Action committees to develop proposed changes to the International Mechanical Code (IMC) and International Fire Code (IFC). The group will address safety and code requirements for restaurants where customers cook their own food, such as tabletop grilling concepts. The proposals could affect ventilation, fire protection and equipment requirements for NAFEM members. To participate or discuss the initiative, contact UL’s Chris Mobley, +1.336.513.7501.

EPR updates

  • The next meeting of NAFEM’s EPR Working Group is Wed., Nov. 18, 2 p.m. CT. All members are invited to register.
  • The Circular Action Alliance (CAA) submitted its revised California program plan to CalRecycle for review, advancing implementation of the state’s packaging extended producer responsibility (EPR) law, SB 54. The plan incorporates public feedback and provides additional details on producer fees, compliance costs and recycling infrastructure investments. California plans to begin producer fee obligations in January 2027, pending regulatory approvals. CalRecycle is accepting public comments through Nov. 13, 2026. NAFEM members can email comments to packaging@calrecycle.ca.gov with the subject line PRO Plan Comments.

CAA also administers EPR programs in Colorado, which began collecting producer fees in January, and Oregon, which launched in July.

PFAS updates

  • New Mexico appealed a federal court’s preliminary injunction blocking enforcement of its PFAS product-labeling requirements, originally scheduled to take effect Jan. 1, 2027. The National Association of Manufacturers (NAM) and other industry groups secured the injunction in September, arguing the requirements violate First Amendment protections against compelled speech. The injunction remains in effect during the appeal, but it does not suspend the state’s separate PFAS reporting requirements or product sales restrictions. NAFEM members should continue monitoring developments and assessing their remaining compliance obligations. PFAS reports are due Jan. 1, 2027; extension requests are due Dec. 2, 2026.
  • The Minnesota Pollution Control Agency (MPCA) continues reviewing and publishing manufacturers’ PFAS product reports following the Sept. 15 deadline. As of Oct. 21, the agency had published approximately 20% of submitted reports, covering nearly 45,000 products, in its PRISM public portal. Manufacturers that received reporting extensions have until Dec. 14, to submit their reports.
  • The regularly updated Complex Products Manufacturers Coalition (CPMC) spreadsheet includes current and proposed state and federal regulations addressing PFAS.