Thu September 29, 2016

SPI has participated in industry consultation and seeks member input for a forthcoming Environmental Protection Agency (EPA) rulemaking to establish fees for administering the Toxic Substances Control Act (TSCA), as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act.

EPA is authorized to collect up to 25% or $25 million (whichever is lower) annually in user fees, from chemical manufacturers (including importers) and processors, to help defray the cost of work associated with various sections of TSCA: 

  • Section 4 – Testing of Chemical Substances and Mixtures
  • Section 5 – Manufacturing and Processing Notices
  • Section 6 – Prioritization, Risk Evaluation and Regulation
  • Section 14 – Confidential Information

 EPA held a public meeting and consultation with industry to help inform the forthcoming proposed rule. Key considerations include: 

  • How fees should be linked to those sections of TSCA
  • Potential changes to costs for pre-manufacture notices (PMNs)
  • Costs associated with filings for exemptions under §5
  • Costs for manufacturers, importers and processors
  • Opportunities for cost sharing through consortia
  • Lower fees for small businesses, and the definition of a small business
  • Potential barriers to innovation
  • Simplicity and transparency

While there is no statutory deadline, EPA intends to propose a rule by mid-December and have a final rule in place by mid-June 2017. Resources include: EPA’s main page on the amended TSCA, the presentation from an Industry Consultation Meeting on Fees, and rulemaking docket

Your input remains invaluable in ensuring SPI members’ views are represented and the plastics industry’s needs are advocated for as this rule and others develop. TSCA is a featured agenda topic for the next EHS+ Committee meeting on October 12-13.

For further information, contact Robert Helminiak, SPI Vice President of Science & Regulatory Affairs ( or Marie Gargas, SPI Senior Technical Director – Environment, Health & Safety (


Founded in 1937, SPI: The Plastics Industry Trade Association promotes growth in the $427 billion U.S. plastics industry. Representing nearly one million American workers in the third largest U.S. manufacturing industry, SPI delivers legislative and regulatory advocacy, market research, industry promotion and the fostering of business relationships and zero waste strategies. SPI also owns and produces the international NPE trade show. All profits from NPE are reinvested into SPI’s industry services. Find SPI online at and

"From resin suppliers and equipment makers to processors and brand owners, SPI is proud to represent all facets of the U.S. plastics industry," said William R. Carteaux, president and CEO, SPI. "Our most recent economic reports show that the plastics industry as a whole is resilient, and has come through the recession significantly better than other U.S. manufacturing sectors."