Skip to main content

Webinar: EPA's TSCA Inventory Reset Rule

Tue, Jun 27, 2017
©2024 Keller and Heckman LLP



By June 22, 2017 EPA is required to publish its final TSCA Inventory "Reset" rule as mandated under the recent TSCA amendments. The draft final version of the rule has reportedly already gone or will go shortly to OMB for review. If finalized as proposed, the final rule will require: 

  • Within 180 days of the date of publication of the final rule, manufacturers and importers must notify all substances they manufactured or imported from June 2006 to June 2016 unless already reported by another company for the 2012 and potentially the 2016 CDR (applies only to substances not claimed confidential on the CDR) or that are otherwise exempt from reporting. Polymer manufacturers and importers will be primarily impacted, along with manufacturers and importers of substances produced below CDR thresholds and companies that submitted CDR reports on substances on the confidential version of the TSCA Inventory.
  • Within 360 days of the date of publication the final rule, processors have the opportunity to report substances that they processed during the relevant 10 - year period to ensure their activities are not disrupted in the event no manufacturer or importer reports a substance.
  • If a substance is not reported, it is considered "inactive" and a notification will need to be submitted 30 days before actual manufacturing or processing begins. 
  • Chemicals added to the Inventory on or after June 22, 2016 are automatically designated "active" and are not subject to notification requirements.

This webinar reviewed key aspects of the final rule with a focus on what changes, if any, EPA has made to the January 13, 2017 proposed rule.

Please click here to view a recording of this webinar.