News
Print PDF

Practice Areas

Advance Notice Requirement Proposed for Imports of Three Chemical Substances

Thursday, October 27, 2016
Sandler, Travis & Rosenberg Trade Report

The Environmental Protection Agency is seeking comments through Nov. 28 on a proposed rule that would impose import restrictions on the following three chemical substances that were the subject of premanufacture notices.

- functionalized carbon nanotubes (generic), which will be used as a thin film for electronic device applications

- diisocyanato hexane, homopolymer, alkanoic acid-polyalkylene glycol ether with substituted alkane (3:1) reaction products-blocked (generic), which will be used as a dual cure/UV cure adhesion/barrier coating for wood substrates

- modified diphenylmethane diisocyanate prepolymer with polyol (generic), which will be used as a raw material for flexible foam

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.

To get news like this in your inbox daily, subscribe to the Sandler, Travis & Rosenberg Trade Report.

Customs & International Headlines