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Advance Notice Proposed for Imports of Trichloroethylene

Friday, August 07, 2015
Sandler, Travis & Rosenberg Trade Report

The Environmental Protection Agency is proposing a significant new use rule for trichloroethylene, which would require persons who intend to manufacture (including import) or process this substance for use in a consumer product to notify the EPA at least 90 days before commencing that activity. There would be an exception, however, for the use of TCE in cleaners and solvent degreasers, film cleaners, hoof polishes, lubricants, mirror edge sealants and pepper spray.

This proposal may also affect certain entities through pre-existing import certification and export notification rules under the Toxic Substances Control Act. Persons who import any chemical substance governed by a final SNUR are subject to the import certification requirements at 15 USC 2612 and the corresponding regulations at 19 CFR 12.118 through 12.127. Those persons must certify that the shipment of the chemical substance complies with all applicable rules and orders under TSCA, including any SNUR requirements. In addition, any persons who export or intend to export TCE on or after Sept. 8 are subject to the export notification provisions of 15 USC 2611(b) and must comply with the export notification requirements in 40 CFR part 707, subpart D.

Comments on this proposal are due no later than Oct. 6.

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