EPA May Extend March 27 Deadline to Self-Identify as a Manufacturer or Importer of a High-Priority Chemical – Update from Bergeson & Campbell, P.C.

On February 24, 2020, the U.S. Environmental Protection Agency (EPA) hosted a conference call to review certain provisions of the final rule on fees for the administration of the Toxic Substances Control Act (TSCA), particularly those related to EPA-initiated risk evaluations.  EPA published a Federal Register notice on January 27, 2020, identifying the preliminary lists of manufacturers (including importers) of the 20 high-priority chemical substances for risk evaluation for which fees will be charged.  85 Fed. Reg. 4661.  During the comment period, currently scheduled to end on March 27, 2020, manufacturers (including importers) are required to self-identify as manufacturers of a high-priority substance irrespective of whether they are included on the preliminary lists identified by EPA.  Where appropriate, entities may avoid or reduce fee obligations by making certain certifications consistent with the final rule on fees for the administration of TSCA. For more information, please read the full memorandum.

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