EPA Proposes New Reporting Rules for Chemical Uses
Published Date: 6/10/2026
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 need to watch the July 10, 2026 deadline to share your plans and avoid delays or fines.
Analyzed Economic Effects
6 provisions identified: 0 benefits, 6 costs, 0 mixed.
High SNUN Submission Costs
If you submit a SNUN, EPA estimates the cost to prepare and submit one SNUN is about $45,496 for a large business and $14,976 for a small business. Submitting businesses must also pay a user fee of $37,000 (or a reduced fee of $6,480 for small businesses as defined at 13 CFR 121.201).
90‑Day Notice Before New Uses
If you plan to manufacture (including import) or process any chemical listed in this proposed rule for an activity the rule calls a “significant new use,” you must notify EPA at least 90 days before starting that activity. You may not begin the activity until EPA reviews your Significant New Use Notice (SNUN), makes a determination, and takes any required action.
June 10, 2026 Cutoff for Ongoing Uses
EPA designates June 10, 2026 as the cutoff date for whether a use is ongoing. Persons who begin manufacture or processing of a listed substance for a significant new use on or after June 10, 2026 would have to stop that activity when the final rule becomes effective and must comply with SNUR notification requirements to resume.
Mandatory Protective Measures and Limits
The proposed SNURs identify absence of the TSCA Order protective measures as a significant new use. Required protections across the listed substances include use of personal protective equipment, hazard communication and Safety Data Sheets, prohibitions on use in consumer products, inhalation exposure controls, respirator requirements (examples: NIOSH‑certified respirator with APF ≥1,000 or APF ≥50 for specific substances), production or concentration limits (examples: concentration limits of 5% or 3% by weight in formulations), particle size or percent‑by‑weight thresholds, and surface water release limits (examples: 669 ppb, 9 ppb, 0.7 ppb, 58 ppb, 3143 ppb, 89 ppb, 316 ppb for various substances).
Testing Expectations and Regulatory Risk
EPA may request or require testing data when reviewing a SNUN and encourages early consultation; submitting a SNUN without test data may increase the likelihood EPA will take action under TSCA sections 5(e) or 5(f). EPA also encourages use of alternative test methods (New Approach Methodologies) where available.
Export Notification and Per‑Country Cost
If you export a listed substance on or after July 10, 2026, you must provide a one‑time export notification to EPA for the first export or intended export to a particular country under TSCA section 12(b). EPA estimates the per‑notification cost is approximately $106.
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