TSCA in transition: What companies need to know now

TSCA

The US Toxic Substances Control Act (TSCA) is facing significant changes. For manufacturers, importers, and supply chain managers, this means new reporting requirements, stricter risk management rules, and possible reforms. Here are the key points:


1. Fee regulation expires – reforms possible

The EPA’s authority to collect TSCA fees ends in September 2026. Industry associations are calling for comprehensive reform, while environmental groups warn of a weakening of chemical protection. Companies should keep an eye on possible changes.


2. New risk management rules and assessments

  • Section 6 (existing chemicals):
    • Court rulings on methylene chloride and chrysotile asbestos expected.
    • Planned rules for perchloroethylene, trichloroethylene, carbon tetrachloride.
    • Finalization for 1-bromopropane, NMP, and Pigment Violet 29.
    • Proposals for formaldehyde, HBCD, and other substances to follow.
  • Section 6 evaluations:
    • Finalization for two chlorinated solvents, new evaluations for nine substances.

3. PFAS reporting requirements

Under TSCA Section 8(a)(7), manufacturers and importers of PFAS must report comprehensive data between April and October 2026. The EPA is considering relief (e.g., exemptions for articles), but companies should prepare for full reporting requirements.


4. Changes to new registrations (Section 5)

The EPA is tightening the requirements for Premanufacture Notices (PMNs) and Significant New Use Rules (SNURs), especially for PFAS and persistent chemicals. New SNUR batches are already in effect.


5. Transparency and CBI deadlines

The 10-year deadline for Confidential Business Information (CBI) is expiring. Companies must submit renewal applications in a timely manner to ensure the protection of confidential data.


6. Inter-agency cooperation EPA ↔ OSHA

Coordination between the EPA and OSHA is being restructured to better coordinate chemical safety in the workplace.


Recommended actions for companies

  • Prepare PFAS reporting requirements
  • Follow new risk management rules
  • Adjust PMN/SNUR processes
  • Review CBI claims
  • Monitor regulatory reforms

2026 will be a key year for TSCA compliance. Those who respond early will minimize risks and remain capable of acting.


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