Publication of the Updated TSCA Inventory

18 April, 2018

What's Happening?

The United States Environmental Protection Agency (US EPA) recently published the updated public version of the Toxic Substances Control Act (TSCA) Inventory.  The US EPA regularly updates the inventory every 6 months.  This current version now includes a field which designates chemicals that are “active” in U.S. commerce.  The designation of “active” was based on the following:

  • Substances reported during the 2012 and 2016 Chemical Data Reporting (CDR) cycles
  • Notices of Commencement received by the agency since June 21, 2006
  • Notice of Activity Form A’s (NOA Form A) received through February 7, 2018, which was the deadline for manufacturer/importer reporting under the TSCA Inventory Update rule.

The US EPA has also made available the list of substances which were reported as “active” after the February 7 deadline.  This list includes substances reported from February 8, 2018 through March 30, 2018.


How Could it Impact Me?

The publication of this updated TSCA Inventory will provide processors with an opportunity to review the substances designated as “active” and submit an NOA Form A on any chemical substance not designated as such.  Processors have until October 5, 2018 to submit an NOA Form A to have a chemical substance listed as “active”.

Electronic reporting is also required from persons who intend to manufacture, import or process an inactive substance for a non-exempt commercial purpose.  In this case, a Notice of Activity Form B (NOA Form B) will be submitted and will need to include chemical identity and the date when manufacturing, importing or processing is anticipated to resume.  The NOA Form B will need to be filed no more than 90 days before the anticipated date of manufacturing, importing or processing.



Reportable Chemicals for Retroactive Reporting

For processors, reportable chemicals will include substances listed on the TSCA Inventory that were manufactured or imported for a non-exempt commercial purpose during the “lookback period” (June 21, 2006 through June 21, 2016) and:

  • Were added to the TSCA Inventory prior to June 21, 2006
  • Are not currently listed as “active” substances
  • Are not naturally occurring materials
Recordkeeping Requirements
  • Records relevant to retrospective reporting (NOA Form A) must be retained for a period of 5 years beginning on the last day of the submission period.
  • Records relevant to forward-looking (NOA Form B) must be retained for a period of 5 years beginning on the day that the notice is filed.


Contact Us

knoell USA can help you determine what your company's obligations are as defined by the TSCA Inventory Notification (Active-Inactive) Requirements.  We can provide an interpretation of these requirements and assist you with the identification of your reportable chemicals.  We can also provide assistance in completion of Notice of Activity Forms A and B.


References and Related Documents

Public Version of the TSCA Inventory

List of Substances Reported in NOA-A from  February 8 through March 30

Final Rule - TSCA Inventory Notification Requirements

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