Toxic Substance Control Act (TSCA)

TSCA requires a company to verify that all chemicals that are manufactured, imported, processed, or distributed in the United States to be listed on the TSCA inventory or meet one of the allowed exemptions.

Aegis Environmental Strategies offers comprehensive support for clients facing the most stringent TSCA compliance requirements and complying with the laws and regulations relating to the commercialization of new and existing chemical substances throughout the US.

Examples of the TSCA range of services include the following:

  • PMN (Pre-Manufacture Notifications): Prepare and submit new chemical notifications.  The PMN application is used to obtain EPA approval and to have a chemical listed on the TSCA inventory. The PMN allows a chemical to be imported or manufactured in the US. The primary benefit of the PMN is unlimited production levels.
  • LVE (Low Volume Exemption): The LVE application is used to obtain EPA approval for use of a chemical at specific volume levels between 2.2 – 22,000 lbs/ year.
  • SNUR (Significant New Use Restriction): Chemicals identified by the EPA with a SNUR have restrictions on use. A Significant New Use Notice (SNUN) may be required for a companies “new use”. Prior to submitting a SNUN, Aegis Environmental Strategies, Inc. will review the new use and determine whether a SNUN is required.
  • Significant New Use Notice (SNUN): Prepare and submit a SNUN application.
  • R&D exemption: Assist company with a procedure for using the R&D exemption including customer notification and record keeping;
  • Polymer Exemption: Evaluate whether a chemical meets the Polymer exemption criteria. If the exemption criteria are met, the chemical is in compliance with TSCA.
  • Chemical Data Reporting (formerly Inventory Update Rule (IUR) reports. Required every 4 years for listed chemicals exceeding established thresholds.
  • Bona Fide Intent to Manufacture or Import: This is a method to ask the EPA to search for a chemical on the Confidential TSCA inventory. A chemical listed on the Confidential TSCA inventory is in compliance with TSCA and meets the EPA’s requirement for manufacturing or import.