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Forest Products Industry Newsletter – June 2026

Home / Forest Products Industry Newsletter – June 2026

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Emerging Regulatory and Technical Topics

  • We are anticipating that U.S. EPA will sign the final revisions to the Plywood and Composite Wood Products (PCWP) rule (40 CFR Part 63, Subpart DDDD) on June 30 to meet their court-ordered deadline. The final rule will establish first time standards for various processes at lumber mills and other composite wood products plants. ALL4 will work with the American Wood Council and NCASI to review the final rule, evaluate how U.S. EPA responded to industry comments, and plan for a fall workshop on the rule revisions. Reach out if you need help understanding how this rule will change things at your wood products facility.

  • U.S. EPA recently issued proposed revisions to the term “begin actual construction” under the New Source Review (NSR) rules. The proposal aims to expand the list of activities that are allowed prior to receiving an NSR permit. Comments on the proposal are due at the end of June – our recent article discusses the proposal. If you are submitting comments, make sure to provide examples of how the change would positively impact your projects!

  • U.S. EPA has sent a proposed rule titled “Revisions to the public participation requirements in minor new source review permitting” to the White House Office of Management and Budget (OMB) for review. We’re not sure what this rule will contain, but watch for an ALL4 blog after it gets published and it could be very important to work with your industry association to provide comments on the proposal.

  • U.S. EPA has taken several actions related to Title V permitting recently, including two guidance memos, a new website with an interactive permitting authority map, and a direct final rule that rescinds a 2023 rule that removed the affirmative defense provisions from the Title V program. The overall goal of these actions is to streamline the Title V application and review process. We are still waiting on a final Title V applicable requirements rule (U.S. EPA proposed the rule in December 2023).

  • U.S. EPA missed the date for designations under the lower annual PM2.5 National Ambient Air Quality Standard (NAAQS) and has been sued. They are currently waiting on the D.C. Circuit court to determine if their 2024 reconsideration of the 2020 NAAQS was legal. If the court determines that it was not, then the NAAQS will revert to the 2020 level. If the court determines that it was legal, U.S. EPA will likely begin a reconsideration of the 2024 action that lowered the NAAQS. Other upcoming NAAQS regulatory actions include lead, NO2, and ozone.

  • U.S. EPA recently proposed changes to the refrigerant rules, but these changes are not likely to affect forest products facilities. The changes will mostly affect refrigerated transport, semiconductor manufacturing, retail food refrigeration, cold storage warehouses, and residential and light commercial heat pump systems. The requirements for certain refrigeration appliances with 15 pounds or more of hydrofluorocarbons (HFCs) that came into effect on January 1, 2026 are still applicable. Reach out if you need clarification or compliance assistance!

  • U.S. EPA has put forth new opinions on its obligations when reviewing 40 CFR Part 63 National Emission Standards for Hazardous Air Pollutants (NESHAP) that could affect how significant revisions to the pulp and paper NESHAP Subparts S and MM will be as a result of the required technology reviews and the LEAN court decision. Of interest, U.S. EPA rescinded (or proposed to rescind) certain NESHAP revisions as not necessary and too costly, and has proposed that they are not obligated to expand the affected source and do gap filling for unregulated units. Of course, it remains to be seen whether these new interpretations will stand up in court.

  • Need help with the New York GHG Reporting Rule? ALL4 staff are helping several facilities understand compliance obligations and implement required monitoring and recordkeeping. This rule is more stringent than Part 98, so don’t assume that you are good to go just because you’ve been doing Part 98 reporting for years. Reach out to Louise Shaffer for assistance.

  • Speaking of Part 98 GHG reporting, U.S. EPA is not on track to finalize the repeal of Part 98 reporting requirements that apply to forest products facilities until just before the extended reporting deadline of October 30, 2026. This will leave many facilities facing the dilemma of whether to go ahead and prepare the report if the rule is not rescinded before October. Watch for the rule to hit OMB in late summer for a hint on when it might be finalized.

  • Public comment periods have now ended for both proposed measures on the Clean Water Act (CWA) Hazardous Substances Facility Response Plan (FRP) rule – now we anxiously await final action on potential delay and changes to the rule aimed at clarifying applicability determinations and implementation of the rule.

  • In our last issue we reported on delays in renewing the U.S. EPA Multisector General Permit (MSGP) for stormwater discharges – the delay continues, and we are now hearing it is largely due to comments received on “additional implementation measures” that are triggered when benchmarks are exceeded. For facilities needing new stormwater permit coverage (or for change in owner, etc.) while the permit is expired and administratively continued, U.S. EPA is providing “No Action Assurance” (NAA) which “establishes the conditions that eligible operators must satisfy, including complying with the requirements of the 2021 MSGP, such that EPA will exercise its enforcement discretion…”

  • On May 18, 2026, U.S. EPA announced a proposal to officially rescind drinking water limits related to four index PFAS compounds and another proposal to propose a process for individual water systems to apply for a two-year extension to comply with standards for PFOA and PFOS. Both proposals are out for 60-day public comment periods with a pubic hearing scheduled for July 7, 2026.

Industry News

Below are some recent forest products industry headlines you might find interesting.

  • June 1, 2026 | Producers just passed a major packaging EPR deadline. Now what? Read more

  • May 29, 2026 | AF&PA Releases 66th Annual Paper Industry Capacity and Fiber Consumption Survey Read more

  • May 27, 2026 | Nippon Paper assessing impacts after deadly Washington mill implosion Read more

  • May 26, 2026 | Breaking Ground: New Sustainable Packaging Facility Coming to Mississippi Read more

  • May 7, 2026 | Automation takes center stage at Smurfit Westrock ‘superplant’ in Wisconsin Read more

  • May 19, 2026 | Sylvamo Eastover Mill Investments Continue Making Progress Read more

  • May 13, 2026 | Smurfit Westrock introduces 2030 sustainability goals Read more

  • May 5, 2026 | Twin Rivers Paper Has Acquired Potsdam Specialty Paper in New York Read more

  • May 4, 2026 | Producers launch second wave of containerboard price increases in 2026 Read more

  • April 26, 2026 | Mondi Opens New Paper Bag Plant in Pittsburgh, Pennsylvania Read more

  • April 17, 2026 | Suzano Launches Newly Developed Brown Eucalyptus Pulp Known as Eucanatural Read more

  • April 10, 2026 | Clearwater Paper Reduces SBS Production at its Arkansas Facility Read more

  • April 6, 2026 | PCA to Close Corrugated Packaging Plant in Richmond, Virginia Read more

  • March 25, 2026 | Domtar to Indefinitely Idle Fluff Pulp Mill in Coosa Pines, Alabama Read more

Safety Corner

As summer approaches, it’s time to for you to take action to ensure your organization is ready to beat the heat. Employers should ensure that they have an effective heat illness prevention program. At a minimum, employers should consider whether their program addresses:

Program Element  Employer Action 
Heat Monitoring  Track heat index, indoor heat sources, workload, PPE, and weather alerts. 
Water and recovery  Provide cool potable water and access to shaded or cooled recovery areas. 
Rest breaks  Build rest periods into work schedules based on heat, workload, and acclimatization status. 
Acclimatization  Gradually increase exposure for new workers, returning workers, and employees returning from extended time away. 
Training  Train employees and supervisors to recognize symptoms, report concerns, and respond to heat illness. 
Emergency response  Establish clear procedures for first aid, medical response, and escalation. 
Documentation  Maintain records of training, heat-related incidents, inspections, corrective actions, and program reviews. 

These elements align closely with OSHA’s stated focus areas in its revised National Emphasis Program (CPL 03-00-024), including cool water, rest, cool areas, training, and acclimatization. They also align with OSHA’s proposed standard on Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings which would require employers to evaluate and control heat-related hazards through a written plan if finalized. Reach out to John Kelleher for more information or for assistance reviewing and updating your safety programs.

Recent Relevant ALL4 Webinars/Podcasts

We’ve reinvigorated our podcast series and thought you’d be interested in the following recent topics:

Recent webinars include the following topics:

If you have a suggestion for a podcast or webinar topic please reach out!

Upcoming ALL4 Events/Conferences

We’re looking forward to the NCASI annual conference this month and hope to see you there! ALL4 staff are presenting in the wood products, air, and water sessions and we’ll have an exhibit booth. In the meantime, we will be out and about at these events:

Training

Do you need professional development hours or have new environmental staff you need to train? Is training in your budget for 2026? If you have budget on a general assistance project with ALL4 you can also use it to register for training – reach out to your project manager for information and a client discount code. Here are some options:

  • WASTE 101 provides a foundational knowledge of various waste-related regulatory programs, with an emphasis on the Resource Conservation and Recovery Act (RCRA). The program covers the history of waste-related regulations and an overview of regulatory programs that impact industrial operations in various sectors, including forest products. You can register and listen to the recordings of our Fall 2025 sessions.
  • Air Quality 101 (AQ101) Training provides a comprehensive and foundational knowledge of the Clean Air Act (CAA) and its various regulatory programs.  The program covers the history of the CAA, NAAQS, and an overview of regulatory programs that impact industrial operations (e.g., New Source Performance Standards, Prevention of Significant Deterioration, air quality modeling, etc.).  The program also covers more focused topics that are encountered day to day by facility environmental personnel such as the basics of emissions testing and continuous emissions monitoring. Our Fall 2025 program is in progress now – you can listen to recordings of early sessions to catch up.
  • WATER101 provides a foundational knowledge of various water-related regulatory programs, with an emphasis on the Clean Water Act (CWA). The program covers the history of water-related regulations, water quality protections, and an overview of regulatory programs that impact industrial operations (wastewater permitting and discharge, stormwater permitting and discharge, contingency and response plans, and drinking water and water resources). The topics covered by WATER101 will be those encountered by environmental personnel in their real-world projects. Recordings of our Spring 2025 sessions are available now and we will offer this course again in 2026.

ALL4 can develop customized EHS training programs for your staff – reach out to Lindsey Kroos for information!

Upcoming Regulatory Deadlines

Do you have electronic reports due soon? Be sure to check the U.S. EPA Compliance and Emissions Data Reporting Interface (CEDRI) templates and the Electronic Reporting Tool (ERT) for updates.

  • The 40 CFR Part 98 GHG reporting deadline has been extended from March 31, 2026 to October 30, 2026. EPA may finalize a rule to discontinue reporting before that date – stay tuned!

  • The TRI submittal deadline is July 1. We go over some beset practices in our recent webinar.

  • Quarterly compliance reports, if applicable to your site, are due in July.

  • Semiannual compliance reports are due in July – check your permit to see if they are due July 30 or 31.

  • Check your air permit to see when your annual compliance certification is due. Need a better compliance tool? We can help.

  • Check your state’s requirements to see if you have an annual emissions inventory due in 2026 and when. Does your emissions inventory need a refresh? We can help.

What’s Happening with Packaging EPR Requirements?

Packaging Extended Producer Responsibility (EPR) laws are moving into active implementation across the U.S. Companies that sell or distribute covered packaging, paper products, or food service ware in EPR-enacted states may now face registration, reporting, fee, and other compliance obligations. Six states (CA, CO, MD, MN, OR, WA) have enacted legislation that currently falls within the Circular Action Alliance (CAA) reporting framework, while Maine remains on a separate, later implementation timeline.

For the current reporting cycle, enacted packaging EPR states generally fall into three categories:

Full Annual Supply Reporting Simplified Reporting Separate/Later Timeline
California, Colorado, Orgeon Maryland, Minnesota, Washington Maine

Full annual supply reporting requires more detailed state-specific packaging data, while simplified reporting uses broader material categories for states that are still earlier in implementation. Maine is not currently part of the six-state CAA reporting framework. Companies with products sold across multiple states should not assume that one report type, one deadline, or one implementation schedule applies everywhere.

Companies that sell or distribute packaged goods into enacted EPR states should consider the following steps:

  • Determine if the rule applies to you (sometimes applicability is based on whether you are supplying packaged goods directly to consumers but sometimes applicability is more broadly defined);

  • Evaluate whether you are the legally responsible producer;

  • Confirm whether you fall into a full reporting, simplified reporting, or later-timeline state;

  • Identify packaging data needed for reporting;

  • Evaluate whether a new or updated digital solution is required for managing and reporting data; and

  • Track upcoming registration, reporting, fee, and participation obligations and deadlines by state.

We can help you navigate the growing complexity of packaging EPR compliance by assessing applicability, evaluating producer responsibility, tracking state-specific deadlines, and supporting packaging data and reporting needs. We can also assist with coordination across internal teams and external stakeholders, as well as broader strategies related to packaging compliance and overlapping regulatory requirements. For assistance, contact Cambre Codington at ccodington@all4inc.com or Louise Shaffer at lshaffer@all4inc.com.

In this time where there is a steady stream of regulatory and deregulatory news, stay tuned for ALL4 updates in our weekly newsletter, 4 The Record. Please reach out if you have any questions or suggestions for our next quarterly Forest Products newsletter.

Thanks,

Amy Marshall, Air Quality Practice Director

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