TSCA – Retrospective reporting deadline for processors is October 5, 2018

The Toxic Substances Control Act (TSCA) mandates EPA to designate substances on the TSCA Chemical Substance Inventory as either “active” or “inactive” in U.S. commerce. To achieve this, EPA finalized a rule that requires industry to report chemicals manufactured, imported, or processed in the U.S. over the ten-year “lookback” period ending on 21 June 2016. This reporting will be used to identify chemicals on the TSCA inventory that are active in U.S. commerce and help determine which chemicals are high priority for risk evaluation.

 

The 7 February 2018 deadline for manufacturers and importers to notify chemical substances as active has expired. Companies that do not manufacture or import chemicals but acquire and blend or react them are not required to submit a notice, however they may do so voluntarily. Processors that plan to report substances processed during the lookback period must submit by 5 October 2018. If your company processes a chemical that cannot be located on the draft TSCA inventory, you may submit your own retrospective report as a safety net. This will help to eliminate the possibility of supply chain interruptions due to inadequate reporting by the manufacturer or importer.