EPA Demands 90-Day Heads-Up for New Chemical Tricks
Published Date: 11/3/2025
Rule
Summary
The EPA is setting new rules for certain chemicals that need a heads-up 90 days before anyone makes or uses them in new ways. This gives the EPA time to check if the new use is safe before it starts. These rules kick in on January 5, 2026, and affect companies making or importing these chemicals, so they should plan ahead to avoid delays or extra costs.
Analyzed Economic Effects
7 provisions identified: 0 benefits, 7 costs, 0 mixed.
90‑Day EPA Notice Before New Uses
If you plan to make, import, or process 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. This 90‑day pre‑notification requirement takes effect January 5, 2026.
SNUN Submission Costs and Fees
Submitting a significant new use notice (SNUN) is estimated to cost about $45,000 per submission for large businesses and about $14,500 per submission for qualifying small businesses. The rule references user fees of $37,000 for larger submitters and a reduced fee of $6,480 for qualifying small businesses.
Recordkeeping and SNUN Time Burden
If you submit a SNUN, EPA estimates the annual burden averages between 30 and 170 hours per submission for tasks like gathering data and completing forms. Recordkeeping requirements in Sec. 721.125 (specific paragraphs referenced) apply to manufacturers, importers, and processors of the listed substances.
Cutoff Date and Cease/Resumption Rule
EPA set April 4, 2025 as the cutoff date to determine whether a use was ongoing. If a person began commercial manufacture (including import) or processing for a designated significant new use after the proposed rule publication and before the final rule’s effective date, they must cease that activity on the final rule’s effective date and may only resume after complying with SNUR notification requirements.
Concentration and Use Thresholds Trigger SNURs
The SNURs set explicit concentration and use thresholds that trigger the SNUN requirement. Examples: processing or using certain substances in consumer products above 1% by weight is a significant new use for multiple entries; for PMN P-20-87 a 3% or greater formulation concentration in consumer products is a significant new use and some provisions set a 1.0% concentration cutoff; for some substances a 0.1% concentration of a confidential component in a consumer product triggers SNUR coverage.
Water‑Release Deactivation Requirement (Thermomycolin)
For thermomycolin (PMN P-22-59), releasing the substance or any waste stream containing it into water is a significant new use unless the substance is deactivated before release. The specified deactivation method is adjusting pH to 2 or below and incubating for 30 minutes.
Export Notification Cost Per Country
If you export a listed substance, 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 is about $106.
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