Reporting Period Begins for EPA Preliminary Lists of Manufacturers Subject to TSCA Risk Evaluation Fees


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On January 27, 2020, the U.S. Environmental Protection Agency (EPA) published its preliminary lists of manufacturers and importers subject to the $1.35 million fees for the 20 high priority substances undergoing risk evaluations. The manufacturers and importers named in the list for each substance, as well as any other companies that manufactured or imported the substances in the preceding five years, are required to submit a notice to EPA within 60 days. Companies who fail to self-identify are subject to per day penalties.

Under section 6 of the Toxic Substances Control Act (TSCA), EPA is conducting risk evaluations on 20 substances designated as high priority. The identities of these substances are provided at the end of this article, including links to EPA’s preliminary lists of manufacturers. Manufacturers and importers of these substances are subject to risk evaluation fees and, critically, there are no exemptions. While companies that exclusively manufactured a substance for uses outside the scope of TSCA[1] are not subject to the fees, substances manufactured or imported as byproducts, articles, or impurities are subject to the TSCA risk evaluation fees. 

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