Advance Notice to EPA Required to Import 24 Chemicals

Trade Update • October 5, 2022

s of November 28, 2022, importers and manufacturers will be required to notify the Environmental Protection Agency (EPA) at least 90 days before importing, manufacturing, or processing any of 24 chemical substances for an activity designated as a significant new use.

Under this proposed significant new use rule (SNUR), anyone involved in the importation, manufacturing, or processing of those 24 chemical substances must wait until the EPA conducts a review of the notice, makes an appropriate determination, and takes actions as required with that determination.

This SNUR was issued by the EPA under the Toxic Substances Control Act (TSCA) for chemical substances which were the focus of premanufacture notices (PMNs). The ruling covers four main subjects: environmental protection, chemicals, hazardous substances, and reporting and recordkeeping requirements.

Importers are required to certify that shipments of these chemical substances comply with all applicable rules and orders under the Toxic Substances Control Act, including any SNUR requirements.

On the other hand, exporters of any of those 24 chemical substances are subject to the export notification provisions of 15 U.S. Code § 2611 (b) and must comply with the export notification requirements in 40 CFR Part 707 Subpart D.

For questions about import requirements, import/product applicability and impact, please contact us.


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