Final TSCA Inventory Notification Rule Published

The U.S. Environmental Protection Agency (EPA) on August 11 published in the Federal Register the Final TSCA Inventory Notification Rulecommonly called the Inventory Reset or Active-Inactive Rule. 

The Industry Reset Rule requires reporting of chemicals manufactured, processed or imported in the U.S. since June 22, 2006 – June 22, 2016. The rule also defines reporting procedures for manufacturing activities post June 22, 2016. With Federal Register publication, the rule becomes effective, and the reporting timelines defined in the rule for required submissions begin. This is Day 1 of the regulatory clock. The interim list of Active Substances can be found on EPA's website

The final rule reflects changes based on the comments EPA received from a variety of stakeholders. Many of the revisions provide clarifications on procedures and enhance definitions. It is expected these changes will streamline the reporting process, but the substance of the final rule remains as in the proposed rule.  

The rule defines and establishes requirements around:

  • Reportable activities and chemical substances, including exemptions from reporting;
  • Timelines for retrospective and forward-looking reporting for both manufacturers and processors;
  • Clear definitions around lookback and forward-looking reporting;
  • Transitional period reporting (the time between June 22, 2016 and the day EPA designates substances as active or inactive);
  • Specific requirements for retrospective and forward-looking reporting including e-submissions and reporting forms; and
  • Treatment of Confidential Business Information requests, including the ability to maintain existing CBI claims for a substance.  
With changes in the administration, there will be a learning curve for both industry and the agency with the new TSCA. However, SOCMA is well positioned to provide updates directly from EPA as the new TSCA moves forward and work with members to navigate Washington’s changing regulatory landscape.  

Please feel free to contact Robert Helminiak at (571) 348.5107, or, if additional information is needed.  

Return Home