Hunch. EPA has put the industry's 18 December 2028 date out for comment, though it says the delay should last no more than one year.
The 2027 market resolves YES if that final rule sets a new ban date later than 31 December 2027, such as the 18 December 2028 that industry asked for, and NO if the new date is 31 December 2027 or earlier. If EPA publishes no such final rule by the end of 18 December 2026, the market is void and does not count.
We looked for cases where EPA proposed moving a date in a chemical ban or limit it had already made final under the Toxic Substances Control Act, the US law on dangerous chemicals. We found five such proposals from 2021 to 2026, and all five became final. They took 123 to 361 days. In four of them an old date was still ahead on the day of the proposal, and EPA finished by that date once. (Federal Register)