EPA Adds More Chemical Notification Rules, Yawn
Published Date: 10/15/2026
Rule
Summary
The EPA is setting new rules that require companies to tell them 90 days before making or using certain chemicals in new ways. This gives the EPA time to check if the new use is safe before it starts. These rules kick in on December 14, 2026, and affect anyone making or importing these chemicals, helping keep people and the environment safe without surprise costs.
Analyzed Economic Effects
6 provisions identified: 0 benefits, 6 costs, 0 mixed.
High SNUN Submission Fees and Costs
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 user fee portion is $37,000 for standard submitters or a reduced small‑business user fee of $6,480 for qualifying small businesses.
90‑Day Pre‑Notice Before New Uses
If you plan to manufacture, import, or process any of the listed chemicals for a use designated as a "significant new use," you must notify EPA at least 90 days before starting. You may not begin the manufacture or processing for that use until EPA reviews the notice and makes a determination.
Time Burden for SNUN Preparation
If you submit a SNUN, EPA estimates the annual burden is between 30 and 170 hours per submission to review instructions, gather data, and complete and submit the SNUN. This time is in addition to any fees or testing that may be needed.
Specific Workplace, PPE, and Use Limits Imposed
For multiple listed chemicals, the rule explicitly requires workplace protections and hazard communication and sets operational limits such as respirator protection factors (e.g., NIOSH APF of at least 1,000 for one substance and at least 50 for another), a concentration cutoff of greater than 5% by weight for one substance, and particle‑size manufacturing limits (e.g., mean particle size ≥2.5 mm or ≤0.01% by weight <1.4 mm). Some entries also require wastewater control technology with 90% removal.
Cutoff Date and Requirement to Cease Interim New Uses
EPA designates June 10, 2026 (the date the proposed rule published) as the cutoff for determining whether a use is ongoing; any use that began after that date and is designated a significant new use must be treated as new. If a person begins commercial manufacture (including import) or processing for a designated significant new use before the final rule is effective, they must cease that activity on the effective date and may only resume after complying with SNUR notification requirements.
Export Notification One‑Time Cost
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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Key Dates
Department and Agencies
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