In January 2025, the U.S. Environmental Protection Agency (EPA) released an updated Toxic Substances Control Act (TSCA) Inventory, now listing 86,847 chemicals, with 42,495 classified as active. This inventory is revised biannually, with the next update expected in summer 2025.

Key Considerations for Exporters to the U.S.

For companies exporting to the United States, the first compliance step is to verify whether their chemical substances are included in the TSCA Inventory. This helps determine their regulatory status as existing substances and associated obligations.

EPA classifies substances as active or inactive under TSCA:

• Active substances are commercially used and prioritized for screening and risk assessment.

• Inactive substances require a Form B submission before production, import, or use to change their status to active.

• Both active and inactive substances are considered existing chemicals under TSCA.

Compliance Duties for Businesses

1. Chemical Data Reporting (CDR)

• Companies producing or importing over 25,000 pounds (11.3 tons) per site must electronically report to EPA via the e-CDR web system.

• CDR reports are due every four years.

2. Significant New Use Notice (SNUR)

• If a substance is designated as a Significant New Use under TSCA, businesses must submit a SNUR to EPA at least 90 days before production or use.

• EPA evaluates SNUR submissions to assess and mitigate potential risks before approving new applications.

Key Takeaway

Businesses must stay updated on TSCA Inventory changes and fulfill compliance duties to ensure smooth market entry into the U.S. while avoiding regulatory penalties.

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