New Chemical Substance Notification Requirements
Summary
EPA is issuing significant new use rules (SNURs) under the Toxic Substances Control Act (TSCA) for certain chemical substances that were the subject of premanufacture notices (PMNs) and a Microbial Commercial Activity Notice (MCAN) and are also subject to an Order issued by EPA pursuant to TSCA. The SNURs require persons to notify EPA at least 90 days before commencing the manufacture (defined by statute to include import) or processing of any of these chemical substances for an activity that is designated as a significant new use in the SNUR. The required notification initiates EPA's evaluation of the conditions of that use for that chemical substance. In addition, the manufacture or processing for the significant new use may not commence until EPA has conducted a review of the required notification; made an appropriate determination regarding that notification; and taken such actions as required by that determination.
Compliance Requirements
- #1
Notify EPA at least 90 days before commencing the manufacture (defined by statute to include import) or processing of any of these chemical substances for an activity that is designated as a significant new use in the SNUR; Submit SNUN on EPA Form No. 7710-25 using e-PMN software in accordance with procedures set forth in 40 CFR 720.40 and 721.25; Pay user fee of $37,000 for large business SNUN submitters or $6,480 for small business submitters as defined at 13 CFR 121.201; Provide one-time export notification to EPA for first export or intended export to a particular country for substances subject to SNUR; Certify that imported chemical substances comply with all applicable rules and Orders under TSCA, including regulations under TSCA sections 5, 6, 7 and Title IV; Cease any commercial manufacturing or processing activity upon effective date of final rule if activity began before final rule effective date for a use designated as significant new use; Submit information required by TSCA section 4 rules, orders, or consent agreements at time of SNUN submission if applicable
Deadline: At least 90 days before commencing significant new use activity
Market Impacts
SNURs create market access barriers by requiring 90-day advance notification (SNUN submission) before manufacturing, processing, or importing chemical substances for designated significant new uses that don't conform to TSCA Order restrictions; Import certification requirements under TSCA section 13 and export notification requirements under TSCA section 12(b) apply to all chemical substances covered by these SNURs; Creatates demand for testing services, compliance consulting, and SNUN preparation services due to notification requirements and potential need for test data development
Estimated Monetary Impact
Basis: The regulation does not provide specific monetary impacts by company size. It only mentions SNUN submission costs ($45,000 for large businesses, $14,500 for small businesses) and export notification costs ($106 per notification), but these are not broken down by revenue thresholds or linked to the provided size definitions. No implementation, ongoing, penalty, or benefit amounts are specified for small, medium, or large companies as defined in the task.Confidence: 10%
Small Companies
< $10M
Costs
Implementation: $0
Ongoing/yr: $0
Penalties: $0
Benefits
Efficiency: $0
New Revenue: $0
Risk Reduction: $0
Net Impact: $0/yr
Medium Companies
$10M - $100M
Costs
Implementation: $0
Ongoing/yr: $0
Penalties: $0
Benefits
Efficiency: $0
New Revenue: $0
Risk Reduction: $0
Net Impact: $0/yr
Large Companies
> $100M
Costs
Implementation: $0
Ongoing/yr: $0
Penalties: $0
Benefits
Efficiency: $0
New Revenue: $0
Risk Reduction: $0
Net Impact: $0/yr
Validated Company Impacts
Air Products & Chemicals, Inc.
Air Products & Chemicals operates as a major manufacturer and processor of industrial gases and chemicals, directly falling under the SNUR requirements for chemical substances. The company's manufacturing, processing, and import activities for chemical products align precisely with the rule's jurisdiction over chemical manufacturers, processors, and importers subject to TSCA regulations. The company's risk factors show no alignment with this SNUR rule, as they focus entirely on financial, operational, and market risks unrelated to chemical manufacturing, processing, or import/export activities. The company operates in technology and digital services with no mention of chemical substances, TSCA compliance, or environmental regulatory risks in their disclosed risk profile.
CABOT CORP
Cabot Corp operates as a chemical manufacturer producing carbon black and specialty chemicals, which directly aligns with the SNUR's focus on chemical substances subject to TSCA regulations. As a manufacturer and likely importer/processor of chemical substances, the company would be subject to the 90-day notification requirements, import certification, and potential cessation of non-compliant activities. The company's sole identified risk factor relates to information technology systems failures, which has no alignment with the chemical substance manufacturing, processing, and import/export compliance requirements of this SNUR rule. The rule addresses environmental and regulatory compliance risks for chemical operations, while the company's disclosed risks focus entirely on IT infrastructure and data security concerns.
Chemours Co
Chemours operates as a leading global manufacturer and processor of performance chemicals across multiple segments including refrigerants, thermal management solutions, TiO2 pigment, and advanced polymers, which directly aligns with the SNUR requirements for chemical manufacturers and processors. The company's extensive chemical manufacturing operations would be subject to the 90-day notification requirements, import/export certifications, and potential cessation of activities for designated significant new uses. The company has only one regulatory compliance risk identified (litigation-related charges), which shows minimal alignment with this chemical substance regulation. The rule's focus on chemical manufacturing, processing, and import/export compliance does not match the company's primary risks of sales decline, goodwill impairment, and financial leverage.
Celanese Corp
Celanese Corp is a global chemical and specialty materials company that manufactures and processes numerous chemical substances, including acetic acid, vinyl acetate monomer, and engineered polymers, which directly aligns with the SNUR requirements for manufacturers and processors. The company operates extensive chemical manufacturing facilities in the US and engages in importing/exporting activities, making it subject to the 90-day notification, certification, and fee requirements. The company identifies environmental regulations as a significant risk factor, which aligns with the EPA SNUR's compliance requirements and potential liability. However, the company's specific environmental risk focus is not detailed enough to confirm direct overlap with chemical substance manufacturing/processing regulations, and other major risk factors like raw material volatility and cybersecurity show no connection to this rule.
DuPont de Nemours, Inc.
DuPont operates as a global innovation leader in technology-based materials and solutions across multiple sectors including electronics, transportation, construction, water, healthcare, and worker safety, all of which involve chemical manufacturing, processing, and importation activities that fall directly under TSCA SNUR jurisdiction. The company's business model of applying diverse science and expertise to develop essential innovations inherently involves chemical substances that would be subject to EPA's significant new use notification requirements. The SNUR rule focuses exclusively on chemical manufacturing, processing, import/export compliance and notification requirements, while the company's only disclosed risk factor is cybersecurity threats in technology. There is no overlap between the rule's chemical regulatory impacts and the company's cybersecurity risk profile.
DOW INC.
Dow Inc. is a major global chemical manufacturer and processor that produces a wide range of chemical substances, placing it directly within the scope of TSCA SNUR requirements. The company's extensive manufacturing, processing, and importing activities for chemical substances would be subject to the 90-day notification requirements, import certifications, and potential cessation of activities for designated significant new uses. The company's risk factors show no alignment with this SNUR rule, as they focus entirely on financial, operational, and market risks unrelated to chemical manufacturing, processing, or import/export activities. The company operates in consumer goods and retail sectors with no mention of chemical production, toxic substances handling, or EPA regulatory compliance concerns in their risk disclosures.
EASTMAN CHEMICAL CO
Eastman Chemical operates as a major chemical manufacturer and processor, directly falling under the SNUR requirements for manufacturing, processing, and importing chemical substances. The company's Additives & Functional Products segment involves chemical production activities that would require EPA notification and compliance with TSCA regulations for significant new uses. The company's disclosed risk factors focus entirely on financial and market volatility risks (currency exchange, commodity pricing, interest rates, derivatives), with no mention of regulatory compliance, chemical manufacturing, or environmental risks. The SNUR rule addresses chemical substance regulation and compliance requirements that do not overlap with the company's identified risk profile.
Element Solutions Inc
Element Solutions is a global specialty chemicals company that manufactures and processes chemical substances as part of its core business operations across both Electronics and Industrial & Specialty segments. The SNUR directly applies to chemical manufacturers and processors, requiring EPA notification for significant new uses of specific chemical substances, which aligns with ESI's chemical production activities. The company has minimal regulatory risk alignment with this SNUR rule, as it only identifies 4 regulatory risks and 8 regulatory compliance risks among its 59 total risk factors, none specifically mentioning chemical substance regulation or TSCA compliance. While the rule creates significant compliance burdens for chemical manufacturers and importers, the company's risk profile focuses primarily on financial, operational, and market competition risks rather than environmental or chemical regulatory compliance.
FMC CORP
FMC Corporation is a global agricultural sciences company that manufactures and formulates crop protection chemicals, including insecticides, herbicides, and fungicides, which directly involves chemical manufacturing and processing activities subject to TSCA SNUR requirements. The company's operations in chemical production, import/export of chemical substances, and development of new chemical formulations align strongly with the rule's focus on manufacturers, processors, and importers of chemical substances. The company's disclosed risk factors show minimal alignment with this SNUR rule, as none specifically address chemical substance manufacturing, processing, or importation requirements. While the company has regulatory compliance risks related to GHG emissions and non-financial disclosures, these are unrelated to TSCA chemical notification obligations. The environmental remediation costs risk is the closest match but relates to legacy site cleanup rather than proactive chemical substance regulation compliance.
Huntsman CORP
Huntsman Corp operates as a global manufacturer of diversified organic chemical products across all three segments (Polyurethanes, Performance Products, Advanced Materials), directly aligning with the SNUR's focus on chemical substance manufacturers and processors. The company's manufacturing and import activities for chemical substances like MDI, amines, maleic anhydride, and epoxy-based formulations would require compliance with the 90-day notification, import certification, and potential cessation requirements for significant new uses. The SNUR rule focuses entirely on chemical manufacturing, processing, import/export compliance, and toxic substance regulation, while the company's only disclosed risk factor is cybersecurity threats related to technology operations. There is no overlap between the rule's chemical regulatory requirements and the company's cybersecurity risk profile.
INNOSPEC INC.
Innospec operates as a manufacturer and supplier of specialty chemicals across multiple segments, directly aligning with the SNUR requirements that target chemical manufacturers, processors, and importers. The company's development and manufacturing of chemical products for fuel specialties and oilfield services would require compliance with TSCA notification and certification requirements for any covered chemical substances. The company's risk profile shows minimal alignment with this SNUR rule, as only one regulatory compliance risk is identified among its top risks, and none specifically address chemical substance manufacturing, processing, or import/export activities that would be directly impacted by TSCA requirements. The company's primary risks focus on market competition, raw material costs, manufacturing disruptions, and technological changes rather than environmental regulatory compliance for chemical substances.
OLIN Corp
OLIN Corp operates as a major chemical manufacturer with significant operations in chlor-alkali products, vinyls, and epoxy materials - all chemical substances that fall under TSCA jurisdiction. The company's manufacturing and processing activities directly align with SNUR requirements for advance notification of significant new uses of chemical substances. The company has only one environmental risk factor identified (Environmental Obligations), which shows minimal alignment with this SNUR rule that specifically targets chemical manufacturing, processing, and import activities. The company's risk profile is dominated by financial and operational risks (27 out of 41 total risks) with no specific mention of chemical regulation compliance or toxic substance handling risks.
PPG INDUSTRIES INC
PPG Industries is a global manufacturer of paints, coatings, and specialty materials, which directly involves chemical manufacturing and processing activities that fall under TSCA jurisdiction. The company's operations in chemical substance manufacturing, importing, and processing align with the SNUR requirements for advance notification and compliance certification. The company's disclosed risk factors are exclusively financial and market-related (currency, interest rates, derivatives), with no mention of chemical manufacturing, environmental compliance, or regulatory risks. The SNUR rule addresses chemical substance manufacturing, processing, and import/export compliance risks that do not overlap with the company's identified financial and market risk profile.
Twist Bioscience Corp
Twist Bioscience operates a chemicals/materials sector producing specialty chemicals and materials, which directly aligns with the SNUR's focus on chemical substance manufacturing and processing. The company's DNA synthesis platform involves chemical manufacturing processes that could potentially fall under TSCA jurisdiction for certain chemical substances. The SNUR rule focuses entirely on chemical manufacturing, processing, import/export compliance requirements and associated financial obligations, while the company's only disclosed risk factor is cybersecurity and IT system disruptions. There is no overlap between the regulatory compliance risks addressed by this chemical substance rule and the company's technology cybersecurity risk profile.
WESTLAKE CORP
Westlake Corp is a major chemical manufacturer and processor with extensive operations in vinyls, olefins, and polyethylene segments, directly falling under the SNUR requirements for manufacturers and processors of chemical substances. The company's import/export activities and large business status align with the rule's notification, certification, and fee requirements. The company's disclosed risk factors show minimal alignment with this SNUR rule. While the company has one regulatory compliance risk (Asset Retirement Obligations), it is not specifically related to chemical substance manufacturing, processing, or importation requirements under TSCA. The environmental risk mentioned is general and not focused on chemical regulatory compliance.