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Attention! New TSCA regulations in the United States: Annual electronic reports for new polymer substances must be submitted by the end of March!


Time:

2024-03-12

The deadline for submitting annual electronic reports on new polymer substances has been extended from January 31, 2024 to March 31, 2024.

The US EPA will extend the deadline for submitting annual electronic reports of polymer new substances that meet exemption criteria from January 31, 2024 to March 31, 2024, in accordance with TSCA regulations.

The TSCA regulations in the United States require manufacturers of new polymer substances produced under exemption clauses (including importers under TSCA regulations) to submit production or import reports before January 31 of the year following initial production. The specific exemption situation is as follows:

01 Extension of submission of exemption report

As early as June 2023, the EPA had amended the exemption reporting requirements, requiring electronic submission of exemption reports and accompanying confidentiality statements.

The report and accompanying confidentiality statement must be submitted electronically using the ePMN application via CDX (cdx. epa. gov).

Due to technical difficulties encountered by the EPA in launching a new electronic reporting tool, the deadline for report submission has been extended to allow manufacturers and importers sufficient time to submit reports and accompanying confidentiality statements using the new tool.

Under the TSCA regulations in the United States, new chemical substances that are not listed on the TSCA list are subject to certain reporting obligations. According to the polymer exemption clause, enterprises can produce new polymer substances that meet the exemption standards without the need to submit pre production notifications or exemption notifications under the TSCA regulatory new chemical substance program.

02 Purpose of polymer exemption clause 

The polymer exemption clause aims to encourage businesses to produce safer polymers by reducing the reporting burden on such chemicals in the industry, and to focus EPA review resources on substances that may pose higher risks.

Polymer new substances that comply with exemption clauses have a record keeping obligation to prove compliance with exemption standards. In addition, producers and importers must submit an annual report stating the quantity of polymers produced or imported under exemption clauses in the previous calendar year, which is the polymer exemption report for this EPA extension deadline.

Therefore, manufacturers and importers applying polymer exemption clauses in 2023 need to pay attention to verifying whether they are affected by this extension of the deadline.

03 Exemption criteria for polymer new houses

👉 Must meet the definition of polymer in 40 CFR 723.250 (b)

For example, if it contains at least 3 monomer units, the molecules must be distributed within a certain range of molecular weight, etc.

👉 And does not meet the exemption exclusion criteria in 40 CFR 723.250 (d), which include:

Polymers that degrade, decompose, or depolymerize;

Polymers prepared from monomers or other reactants not listed on the TSCA list in the United States;

◇ Water absorbing polymer with an average molecular weight of ≥ 10000 Daltons;

Polymers containing perfluoroalkyl moieties (CF3 or longer chain length);

In addition, there are restrictions on cationic polymers and polymer elements.

👉 And meet the criteria of 40 CFR 723.250 (e):

The average molecular weight of the polymer ranges from 1000 to 10000 Daltons. The content of oligomers with a molecular weight less than 500 Daltons shall be less than 10% (w/w), and the content of oligomers with a molecular weight less than 1000 Daltons shall be less than 25% (w/w), but shall not contain highly concerned or highly reactive functional groups;

The average molecular weight of the polymer is ≥ 10000 Daltons. The content of oligomers with a molecular weight less than 500 Daltons is less than 2% (w/w), and the content of oligomers with a molecular weight less than 1000 Daltons is less than 5% (w/w);

If it is a polyester polymer defined by regulations, only one or more reactants from the list of reactants that can produce polyester are produced.

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