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EPA Issues New Non-Complying Lots Guidance for TSCA Title VI

EPA issued today new guidance on non-complying lots under TSCA Title VI.  The guidance clarifies in particular the responsibilities for fabricators, distributors, importers and retailers in the event they have been supplied with a non-complying lot, which are as follows: 

  1. If a company has intact non-compliant panels in inventory, it must work with the panel producer to isolate, treat and retest those panels as needed. 

  2. If the company has further distributed the panels in the supply chain, then that company must notify the purchaser within 72 hours of the time the company was made aware of the non-complying lot by the panel producer. 

  3. If a company has already incorporated non-compliant panels into a component part or finished good, then that company does not have any obligation to notify downstream entities in the supply chain. 

The requirements for panel producers have not been modified. Mills must notify customers within 72 hours of a non-complying event.  After notification, panel producers can choose to:

  • recall the panels belonging to the non-complying lot and treat or retest them (or dispose of them); or

  • treat and retest the panels at their customers place of business.

After recalling or treating/retesting the non-complying lot, panel producers then have seven days to inform their TPC of how the non-complying lot was addressed. 

Based on this EPA guidance, panel producers would not have any responsibility to recall component parts or finished goods containing non-complying panels.  See EPA Guidance.  More Info: Jackson Morrill

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