Chem Rules Get Slimmed Down by EPA
Published Date: 10/28/2025
Proposed Rule
Summary
The EPA is updating rules for certain chemicals to make it easier to use some new applications without extra paperwork, while tightening or tweaking notification requirements based on fresh data. Companies working with these chemicals need to pay attention and comment by November 28, 2025. These changes aim to keep everyone safe without slowing down innovation or adding unnecessary costs.
Analyzed Economic Effects
6 provisions identified: 3 benefits, 2 costs, 1 mixed.
SNUN submission costs and fees
If you or your company wants to pursue a ‘‘significant new use’’ of one of the listed chemicals, you must submit a Significant New Use Notice (SNUN). EPA estimates SNUN submission costs of about $45,000 per SNUN for large businesses and $14,500 for small business submitters, including user fees; the statutory user fee is $37,000 or a reduced small business user fee of $6,480 (per fiscal year 2022). EPA also estimates the paperwork burden for a SNUN is about 30 to 170 hours per submission.
Inkjet fixing agent use now allowed without SNUN
For the chemical at 40 CFR 721.10070 (1,3-butanediol, 3-methyl-), EPA proposes to remove the requirement to notify for use as a fixing agent of ink for inkjet printers. That means using this substance as an inkjet ink fixing agent would no longer be a designated ‘‘significant new use’’ and could occur without submitting a SNUN.
New SNUN triggers and allowances for acrylate monomer
For the chemical at 40 CFR 721.10471 (a UV-coating/printing-ink monomer), EPA proposes to allow certain domestic manufacture and use as described in PMN P-03-622 to occur without a SNUN, but to designate several activities as significant new uses that would require notification. The designated triggers include: use without dermal personal protective equipment; use without a NIOSH-certified respirator with an assigned protection factor (APF) of at least 50; failure to establish a hazard communication program; surface water releases that exceed 11 parts per billion (ppb); manufacture that results in inhalation exposure; use in consumer products; and use other than as a component of specified UV curable coatings, printing inks, additive manufacturing, adhesives, composites, 3D printing, and coating systems. EPA would also add an exemption when the substance has been completely reacted or cured.
Export notification one-time cost
If you export a substance that is the subject of a SNUR, you must provide a one-time export notice to EPA for the first export or intended export to each country. EPA estimates the per-notification cost for export notification is about $106.
Expanded allowed uses for fire-extinguishing agent
For the chemical at 40 CFR 721.10966 (1-Propene, 2-bromo-3,3,3-trifluoro-), EPA proposes to reduce the scope of significant new uses by excluding two additional uses that the PMN submitter requested: streaming in most non-residential uses (except commercial home office and personal watercraft) and niche flooding in unoccupied spaces up to 500 cubic feet (for example, large data storage rooms). Those additional uses would no longer trigger SNUR notification.
Removal of 6-month manufacture restriction after testing
For the chemical at 40 CFR 721.11180 (arenesulfonic acid, alkyl derivatives, metal salts), EPA proposes to remove the significant new use that had prohibited manufacture beyond six months after a notice of commencement because required sensitization testing was completed. Removing that SNUR requirement would allow manufacture beyond the six-month limit without that specific SNUN trigger.
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Key Dates
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