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Imports of Chemical Substances Could Require Advance Notice

Wednesday, July 22, 2020
Sandler, Travis & Rosenberg Trade Report

The Environmental Protection Agency is accepting comments through Aug. 20 on a proposed rule that would require persons who intend to manufacture (including import) or process any of seven chemical substances (see attached for full list) for an activity designated as a significant new use by this rule to notify the EPA at least 90 days before commencing that activity. The substances at issue are used as or in the production of resins, optical film coatings, hardeners, adhesives, hollow fiber products, semiconductors, inks, coatings, and sealants.

Under this rule, importing, manufacturing, or processing these substances for a significant new use could not be commenced until the EPA has conducted a review of the advance notice, made an appropriate determination, and taken such risk management actions as are required by that determination. Importers would have to certify that shipments of these substances comply 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 any of these substances on or after Aug. 20 would be subject to the export notification provisions of 15 USC 2611(b) and have to comply with the export notification requirements in 40 CFR part 707, subpart D.

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