EPA Proposes Alerts for Emerging Chemical Uses Ahead
Published Date: 11/2/2025
Proposed Rule
Summary
The EPA is proposing new rules that require companies to tell them 90 days before using certain chemicals in new ways. This gives the EPA time to check if the new use is safe before it starts. If you make or import these chemicals, you’ll need to follow these rules by December 3, 2025, or risk delays and extra costs.
Analyzed Economic Effects
5 provisions identified: 0 benefits, 5 costs, 0 mixed.
High SNUN Submission and User Fees
If you submit a Significant New Use Notice (SNUN), EPA estimates average submission costs of about $45,000 for large businesses and $14,500 for small businesses. In addition, submitters must pay a user fee of either $37,000 (standard) or a reduced fee of $6,480 if they qualify as a small business.
90‑Day Pre-Notice Before New Uses
If you plan to manufacture, import, or process any listed chemical for a use EPA calls a "significant new use," you must notify EPA at least 90 days before starting that activity. You may not begin the new use until EPA reviews the notification and makes a determination.
November 3, 2025 Cutoff for Ongoing Uses
EPA designates November 3, 2025 as the cutoff date to decide whether a use is ongoing. If a person begins manufacture or processing for a significant new use on or after that cutoff date and the final rule later makes it a SNUR, they would have to stop the activity when the final rule is effective and comply with SNUR notification requirements to resume.
Existing TSCA Order Restrictions Must Be Followed
These SNURs identify as a "significant new use" any manufacturing, processing, use, distribution, or disposal that does not follow the restrictions in the underlying TSCA Orders. Examples of those restrictions include respirator requirements (specified APFs such as 50, 1,000, or 10,000), limits on processing above 5% in formulation, limits on domestic manufacture (import-only), processing only at specified facilities, and release limits (e.g., surface water concentration limits of 152 ppb, 160 ppb, 14 ppb, 6 ppb, or a dust release limit of 8.3 kg/year).
Export Notification and Per-Notice Cost
If you export a chemical listed in this proposed rule on or after December 3, 2025, you must provide a one-time export notification to EPA for the first export or intended export to each country. EPA estimates the per-notification cost at about $106.
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Key Dates
Department and Agencies
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Previous / Next Documents
Previous: 2025-19755 — Significant New Use Rules on Certain Chemical Substances (25-1.5e)
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.
Next: 2025-19757 — Significant New Use Rules on Certain Chemical Substances (25-2.5e)
The EPA is proposing new rules that require companies to tell them 90 days before using certain chemicals in new ways. This gives the EPA time to check if the new uses are safe before they start. If you make or import these chemicals, be ready for extra steps and possible delays starting soon!