A May 2024 report by activist groups revealed that only 39% of Colorado oil and gas wells subject to a 2022 chemical disclosure law had filed required data, prompting state regulators to crack down. By early June, compliance jumped to nearly 90%, signaling tighter enforcement that overseas chemical suppliers and distributors should monitor for potential impacts on product registration and market access.
Compliance gap exposed
The report, issued by Physicians for Social Responsibility Colorado, the Colorado Sierra Club, and the FracTracker Alliance, found that of at least 1,114 wells covered by the 2022 law, chemical disclosures were available for only 439 (39%). The wells are concentrated in Weld County, Colorado’s most active oil and gas region. Chevron and its subsidiaries PDC Energy and Noble Energy operate over half of the 675 non-compliant wells.
Regulatory crackdown and rapid improvement
Following the report’s release on May 20, the Colorado Energy and Carbon Management Commission (ECMC) issued warning letters to non-compliant operators. By May 22, compliance had risen to 56%, and after a May 29 meeting with companies, it reached nearly 90% by June 7. The number of companies reporting chemical disclosures doubled from 11 to 22 during that period.
Disclosure scope and trade secret concerns
The 2022 law requires manufacturers, distributors, and oil and gas companies to disclose trade names and chemical identities of products used in wells, even if trade secrets are involved. However, specific formula proportions can be withheld. Critics note that while fracking chemical compliance is improving, drilling chemical disclosures remain largely absent, raising concerns about groundwater contamination during the initial drilling phase.
PFAS and prohibited chemicals under scrutiny
The law also mandates that manufacturers and distributors attest that products have no intentionally added PFAS (per- and polyfluoroalkyl substances). The ECMC has issued four notices of alleged violation for use of other prohibited chemicals. Activists worry that PFAS may still be used in drilling, but state officials say they have no evidence of current PFAS use in the wells under review.
What buyers should watch
Overseas chemical suppliers to Colorado oil and gas operators should ensure their products comply with the state’s disclosure requirements, including PFAS-free attestations. The rapid enforcement escalation signals that non-compliance can lead to warning letters or alleged violations, potentially disrupting supply contracts. Companies should verify that their downstream customers are filing complete disclosures for all well development phases, not just fracking.
Source: Read the original report | Published: July 20, 2025