EPA Extends Self-Identification Deadline for TSCA Fees
EPA issued a press release last week extending the comment and self-identification period for stakeholders subject to fees associated with EPA TSCA risk evaluations from May 27 to June 15, 2020. As was previously reported in @the edge, EPA has made significant clarifications to the list of responsible stakeholders, most notably announcing a new rulemaking process that will be finalized in 2021 and exempting 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 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. As CPA noted in prior @the edge articles, members that fall into the three categories under the No Action Assurance may still have a limited duty to report on the EPA’s CDX system. See EPA Extension Letter. More Info: Jackson Morrill