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Advance Notice Requirement Proposed for Imports of Three Chemical Substances

Thursday, April 14, 2016
Sandler, Travis & Rosenberg Trade Report

The Environmental Protection Agency is seeking comments through May 13 on a proposed rule that would impose import restrictions on the following chemical substances that were the subject of premanufacture notices.

- isocyanate prepolymer (generic), which is used as an ingredient in an industrial adhesive

- methylene diisocyanate polymer with diols and triols (generic), which is used as an industrial adhesive

- polymer of isophorone diisocyanate and amine-terminated propoxylatedpolyol (generic), which is used as a crosslinker

Under this rule, persons who intend to import, manufacture or process any of these substances for an activity that is designated as a significant new use by this rule would have to notify EPA at least 90 days before commencing that activity.

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 significant new use rule 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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