Toxic Substance Control Act (TSCA) Inventory Reset Compliance

EPA published a final rule to establish notification for retrospective reporting of chemicals on the TSCA Inventory that were manufactured or imported during the 10-year period; between June 2006 and June 2016. The purpose of the rule is to “reset” the TSCA inventory maintained by the EPA.

Here are the highlights:

• The rule requires manufacturers and importers to notify EPA of each chemical substance on the TSCA Inventory that has been manufactured or processed for a non-exempt commercial purpose during the previous ten (10) year period.
• These notified chemicals will then be designated as active substances on the TSCA Inventory.
• This active substance list will then become the new Active TSCA Inventory.
• Only substances on this new Active TSCA Inventory will be allowed for use in commerce, including manufacture, import, and processing. The primary exceptions to this are for substances manufactured or imported under Low Volume, Polymer Exempt or R&D exemptions.
• If a facility does not take action to ensure that each chemical substance in its supply chain is on the active TSCA Inventory, its import or sale for commercial use will not be allowed by EPA.

All manufacturers and importers must take action and file “active” notifications through the EPA Central Data Exchange [CDX]. There are about 87,000 chemicals on the TSCA list. If you have any questions or would like to confirm if the TSCA Inventory Reset rule impacts your facility, contact Sam Joshi at (215) 389-2811.