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EPA Announces Important Changes to TSCA Self-Identification Requirement

The EPA announced yesterday that it intends to clarify the list of stakeholders responsible for covering the $1.35 million fees for each of the 20 recently initiated risk analyses, including formaldehyde.  Specifically, the Agency stated it will initiate a new rulemaking process that will exempt from TSCA’s self-identification requirement stakeholders that:

  • Import the chemical substance in an article;

  • Produce the chemical substance as a byproduct; and

  • Produce or import the chemical substance as an impurity.

EPA plans to issue the proposed amendments to the current TSCA fees rule later this year with the goal of finalizing the amendments in 2021. Importantly for the many CPA members that are impacted by this proposed change, EPA has simultaneously issued a “No Action Assurance” for the above three stakeholder categories, which essentially removes the self-identification requirement until the amendments are finalized in 2021.   

CPA understands that EPA will announce a call or webinar – likely to be the week of April 6 - to review these proposed changes to the self-identification requirement.  CPA will share the date once it is announced.  See EPA No Action Assurance Letter.  More Info: Jackson Morrill

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