Hunton Retail Law Resource

The Toxic Substances Control Act (“TSCA”) authorizes EPA to regulate virtually all aspects of the manufacture, import, distribution and use of chemical substances in the United States. Unlike many of the federal environmental statutes that EPA administers – which target pollution, waste or site cleanup – TSCA regulates chemicals at the product stage both before and after being introduced into commerce. Under TSCA, EPA imposes numerous regulatory obligations on the domestic manufacturer and importer of industrial chemicals. If your company engages in either of these activities, you may have imminent reporting obligations under the TSCA Chemical Data Reporting (“CDR”) rule. Failure to promptly report has been an EPA enforcement focus in past CDR years.

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