More EPA Rules: Notify Us Before New Chemical Ventures
Published Date: 11/2/2025
Proposed Rule
Summary
The EPA is setting new rules for certain chemicals that need a heads-up before anyone makes or uses them in new ways. If you plan to start a new use, you must tell the EPA 90 days ahead so they can check if it’s safe. This affects manufacturers and importers, and you have until December 3, 2025, to share your thoughts on these rules.
Analyzed Economic Effects
6 provisions identified: 0 benefits, 5 costs, 1 mixed.
High SNUN Submission Costs
If you submit a Significant New Use Notice (SNUN), EPA estimates the cost at about $45,000 per SNUN for large businesses and about $14,500 for small businesses; user fees are about $37,000 for large submitters or a reduced $6,480 for small businesses.
90‑Day Notice Before New Uses
If you manufacture or import any listed chemical for a use the rule calls a "significant new use," you must notify EPA at least 90 days before starting that activity and you may not begin the new use until EPA reviews the notice and makes a determination.
November 3, 2025 Cutoff for Ongoing Uses
EPA set November 3, 2025 as the cutoff date to decide whether a use is ongoing; persons who begin manufacture or processing of a listed chemical for a designated significant new use on or after that date would have to stop that activity when the final rule becomes effective and comply with SNUR notification requirements to resume.
Import‑Only Manufacturing Limits for Some Chemicals
For several listed substances (for example P-20-138, P-21-101, P-22-68, and others), EPA's TSCA Orders require manufacture only by import into the U.S. (i.e., no domestic manufacture); the proposed SNURs would make the absence of that restriction a "significant new use" requiring prior EPA notification.
Required Respirators, PPE, and Other Controls
Many of the TSCA Orders for the listed substances require specific exposure controls such as NIOSH‑certified respirators with APFs (for example APF ≥10, ≥50, or ≥1,000 in spray scenarios), personal protective equipment, hazard communication, and limits on releases to surface water (e.g., 1 ppb, 60 ppb, 550 ppb, 32 ppb for various substances); the proposed SNURs would treat the absence of these measures as a significant new use.
Export Notification Requirement from Dec 3, 2025
If you export a listed chemical on or after December 3, 2025, you must follow TSCA section 12(b) export notification rules and provide a one‑time notice to EPA for the first export or intended export to each country, with an estimated cost of about $106 per notification.
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Key Dates
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