Manufacturers and processors have until the 5th August to notify the US Environmental Protection Agency (EPA) to redefine Inactive substances to Active in the TSCA inventory. After this date, using an Inactive substance will be non-compliance unless you submit a NOA-B within 90 days of actual manufacturing or processing an Inactive substance.
TSCA was reformed on the 22nd June 2016 and effects manufacturers, importers and processors including formulators and downstream users. TSCA relies heavily on the TCSA inventory to define new or existing substances in the US commerce. Under TSCA reform the EPA wanted to update the 85000 substances listed on the inventory to reflect substances still active in the US and issued the “The Inventory Reset Rule” (published August 11, 2017). This rule required during 2018 companies to notify the EPA of substances designated as active and any substance not notified would be considered inactive. The revised inventory has only about one-half of the substances designated as active so make sure your check your substances.
H2 Compliance has a dedicated New York office to assist your TSCA needs.
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