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Advance Notice Requirement Proposed for Imports of Two Chemical Substances

Wednesday, August 24, 2016
Sandler, Travis & Rosenberg Trade Report

The Environmental Protection Agency is seeking comments through Sept. 23 on a proposed rule that would impose import restrictions on hydrochlorofluoropropane and hydrochlorofluoropropene (generic) that were the subject of premanufacture notices. Under this rule, persons who intend to import, manufacture or process either 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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