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The US Environmental Protection Agency has proposed a new policy, affecting more than 300 PFAS substances


Time:

2023-02-09

On January 27, 2023, the United States Environmental Protection Agency (EPA) proposed to propose important new use rules (SNUR) for PFAS substances in inactive status in the list of Toxic Substances Control Act (TSCA). It is estimated that there are more than 300 such substances.

On January 27, 2023, the United States Environmental Protection Agency (EPA) proposed to propose important new use rules (SNUR) for PFAS substances in inactive status in the list of Toxic Substances Control Act (TSCA). It is estimated that there are more than 300 such substances. The final establishment of this rule will lead to an increase in the cost of the import activities of more than 300 substances and a longer declaration period.

The TSCA directory is divided into active and inactive according to the active trade status of chemical substances in the United States market. "Inactive" means that the chemical substance has not been produced, imported or processed in the United States since June 21, 2006.

Before that, if such inactive chemicals were to be produced, imported and processed in the United States, they only needed to reset the list and change the inactive status into active, without the need for EPA to conduct a complete review and risk confirmation. The process was simple, rapid and did not involve high administrative costs.

However, if it is necessary to deal with the important new use rules (SNUR), the declaration process is much more complex.

Important new use rules (SNUR), that is, after the EPA of the United States evaluates the chemical substance, it determines the restriction rules for it. If the use of the chemical substance exceeds the limit conditions, the enterprise needs to notify EPA 90 days before the use activity begins, and EPA will evaluate and review the notification. Before the EPA makes a decision on the notice, the enterprise shall not produce, import or process for conditions beyond the limit.

The evaluation and review fee of such notification is equal to the pre-production declaration (PMN), which is $19020, and the cost is high. In addition, the current evaluation and review of such notifications by the EPA is far more than 90 days, so enterprises involving such chemicals and with import intention need to make trade planning as soon as possible.

At present, the rule is in the proposed comment stage, and the EPA has not released a list of more than 300 PFAS substances. However, enterprises can confirm whether the chemical substances are within the scope of the proposed rules through the TSCA directory, and the Ruiou team will also continue to follow up the subsequent release of relevant substances and SNUR rules.

The human health and environmental hazards caused by PFAS substances are bound to face increasingly strict control. Therefore, whether it is based on the consideration of human health and environmental hazards, or in the hope of simpler and smoother import trade activities, the Ruiou team recommends that:

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