Fri September 1, 2017

The Environmental Protection Agency’s final rule on TSCA Inventory Notification (Active-Inactive) Requirements was published on August 11, starting the clock on statutorily mandated deadlines under the amended Toxic Substances Control Act. Manufacturers, including importers, must complete within 180 days (through February 7, 2018) their “retrospective” reporting of chemical substances listed on the Inventory that were manufactured for nonexempt commercial purposes during a 10-year “lookback” period ending on June 21, 2016. EPA will then make available a draft Inventory. Retrospective reporting is optional for processors, who have a 420-day period (through Oct. 5, 2018) and do not need to report chemical substances which had already been reported. The final rule also contains provisions for forward-looking notification to move a chemical substance from inactive to active status. More information including the Interim List of Active Substances is available from EPA. Email Marie Gargas to get involved on TSCA in PLASTICS.