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Import Restrictions Proposed for Seven Chemicals Used in Consumer Products

Thursday, January 15, 2015
Sandler, Travis & Rosenberg Trade Report

The Environmental Protection Agency is seeking comments through March 16 on a proposed rule that would impose import restrictions on seven toluene diisocyanates and related compounds. These chemicals are widely used in residual amounts in the production of polyurethanes and consumer products such as coatings, elastomers, adhesives and sealants and can be found in products used in and around homes or schools.

The proposed significant new use rule would require manufacturers (including importers) to notify the EPA at least 90 days before starting or resuming new uses of these chemicals in consumer products at levels above 0.1 percent by weight. The EPA would then have the opportunity to evaluate the intended use of the chemicals and, if necessary, take action to prohibit or limit the activity. The proposed rule would also apply the advance notification requirement to importers and processors of these chemical substances as part of articles (manufactured goods).

Importers of chemical substances subject to this rule would have to certify their compliance with all applicable rules and orders under the Toxic Substances Control Act, including any SNUR requirements. In addition, any persons who export or intend to export a chemical substance subject to a final SNUR would be subject to the export notification provisions of 15 USC 2611(b) and would have to comply with the export notification requirements in 40 CFR part 707, subpart D.

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