/>iPresident Donald Trump’s initial 100 days in office during his second term have marked a significant shift in the United States’ approach to chemical regulation, emphasizing deregulation and industry facilitation over more traditional environmental and public health safeguards. President Trump’s actions, inactions, and policy choices during his first 100 days seem to have come at a cost, as polls show his approval rating has decreased to 39 percent, an 80-year low for a President’s first 100 days in office.
Deregulatory Initiatives and Industry Impact
Central to the Administration’s agenda is an aggressive deregulatory policy, notably the Executive Order (EO) requiring “that for each new regulation issued, at least 10 prior regulations be identified for elimination.” EO No. 14192, 90 Fed. Reg. 9065. This approach has led to considerable confusion and commercial uncertainty, neither of which appeals to the business sector. Regarding chemical regulation, what has been announced are reviews of Biden Administration work on chemical risk assessments and intended review actions, including extensions of comment periods on chemical assessments.
In March 2025, the U.S. Environmental Protection Agency (EPA) announced its decision to reconsider the regulation governing the review of chemicals already in commerce by initiating a rulemaking “that will ensure the agency can efficiently and effectively protect human health and the environment and follow the law.” This signals a plan that may result in changes to foundational assumptions in the risk assessment methods used in the previous four years.
The Department of Government Efficiency (DOGE) has not been as efficient in its first 100 days as it promised. Rather than saving the taxpayers a trillion dollars, as DOGE initially pledged to the American people, government spending is increasing. Spending increases are due in part to the haphazard way in which DOGE went about cutting whole departments before realizing who they were firing and what programs they were gutting, only to have to rehire employees back again — if they could figure out how to contact them at all, since they had already cut off employee access to federal e-mail accounts. DOGE’s February 2025 cuts to the National Nuclear Security Administration (NNSA) within the Department of Energy (DOE) made headlines, as the hundreds of locked-out employees included those undertaking some of the most sensitive jobs within the U.S. nuclear weapons enterprise.
As far as chemicals go, the premanufacture notice (PMN) review program delays and foundational review policies are under review. Given that the law requires a pre-market review, any program cuts would likely lead to even further decision delays. As a result, notwithstanding industry criticism of the program, there is broad support for adequate budget resources as part of the effort to increase the timeliness and predictability of program decisions.
PFAS Regulation: A Plan for Regulatory Reversal?
Per- and polyfluoroalkyl substances (PFAS), often referred to as “forever chemicals,” have been a focal point in discussions about chemical safety for some time now. The Trump Administration faces a pivotal decision on whether to uphold strict federal drinking water limits for PFAS established during the previous Administration. On April 28, 2025, EPA announced policy updates, including how it plans to “[i]mplement TSCA [Toxic Substances Control Act] Section 8(a)7 ‘to smartly collect necessary information, as Congress envisioned and consistent with TSCA, without overburdening small businesses and article importers’.” In the meantime, many states, most notably Maine, Minnesota, and New Mexico, have introduced robust PFAS restrictions and reporting requirements of their own in an effort to ensure that PFAS are not unnecessarily released into the environment, or found in high-contact products, regardless of federal decisions. While at this point any announcement regarding the fast-approaching July 11, 2025, start of the reporting cycle is welcome, the official update was short on detail.
Environmental Justice and Community Health Concerns
One program area that has so far seen significant and impactful change under this Administration are environmental justice (EJ) measures, such as former President Biden’s Environmental Justice 40 Initiative. The Administration has issued directives across all agencies, including EPA, eliminating Diversity, Equity, and Inclusion (DEI) and other programs and staff deemed “woke.” On President Trump’s first day, he issued the EO Ending Radical And Wasteful Government DEI Programs And Preferencing to begin this effort. EO No. 14151, 90 Fed. Reg. 8339.
Elimination of EJ programs will disproportionately affect minority communities. The termination of programs aimed at protecting these populations from pollution exposure can be expected to increase (or at least not reduce) health risks in areas like Louisiana’s “Cancer Alley,” where industrial emissions have long been a concern. At the same time, reducing and eliminating much of EPA’s climate action programs, designed to reduce the impacts and uncertainties of climate change, will hurt key industries such as agriculture and food production, while more intense storms could adversely affect chemical production facilities along the U.S. coast.
The first 100 days of President Trump’s tenure have ushered in a new era of chemical regulation, characterized by a strong emphasis on deregulation and a leaner federal infrastructure. While proponents argue this fosters economic growth and innovation, critics highlight the potential risks to environmental integrity, public health, and institutional knowledge. As the Administration continues to redefine regulatory frameworks, stakeholders must navigate this evolving landscape with vigilance and adaptability.
