EPA Hands Chemical Firms Extra Months for Toxin Data Dump
Published Date: 3/13/2025
Rule
Summary
The EPA is giving manufacturers and importers more time to send in important health and safety info about 16 chemicals under the Toxic Substances Control Act. The deadline for vinyl chloride is now June 11, 2025, and for the other 15 chemicals, it’s September 9, 2025. This extension helps companies meet the rules without rushing and keeps everyone safer by making sure the EPA gets the data it needs.
Analyzed Economic Effects
4 provisions identified: 3 benefits, 1 costs, 0 mixed.
Vinyl chloride reporting deadline extended
If you manufacture (including import) vinyl chloride (CASRN 75-01-4), the deadline to submit lists and copies of certain unpublished health and safety studies to EPA was changed from March 13, 2025 to June 11, 2025. You must meet the June 11, 2025 deadline for vinyl chloride submissions under the TSCA Health and Safety Data Reporting rule.
Fifteen chemicals: reporting deadline moved to Sept 9
For 15 other listed chemicals, EPA moved the reporting deadline from March 13, 2025 to September 9, 2025. The affected substances are: 4,4-Methylene bis(2-chloraniline) (101-14-4); 4-tert-octylphenol (140-66-9); Acetaldehyde (75-07-0); Acrylonitrile (107-13-1); Benzenamine (62-53-3); Benzene (71-43-2); Bisphenol A (80-05-7); Ethylbenzene (100-41-4); Hydrogen fluoride (7664-39-3); 6PPD (793-24-8); 6PPD-quinone (2754428-18-5); Naphthalene (91-20-3); Styrene (100-42-5); Tribomomethane (Bromoform) (75-25-2); and Triglycidyl isocyanurate (2451-62-9). If you manufacture or import any of these and have unpublished health and safety studies, you must submit the required lists and copies by September 9, 2025.
OECD template (OHT) and CBI claims complicate reporting
EPA said this is the first TSCA section 8(d) reporting where respondents must prepare OECD harmonized templates (OHTs) for study submissions that contain confidential business information (CBI). EPA found companies unexpectedly need to complete many more OHTs (for example because of personally identifiable information in studies) and is allowing extra time and plans to issue more guidance so firms can decide if an OHT is required and prepare any needed OHTs.
Who is covered: manufacturers, importers, and byproducts
The rule applies to manufacturers (including importers) of the listed chemicals, identified NAICS codes include chemical manufacturers (325) and petroleum refineries (324110). The rule applies if you currently manufacture/import a listed chemical, will do so during its reporting period, or have manufactured/imported or proposed to do so within the last 10 years; it also applies to byproducts and impurities produced during other manufacturing.
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