Jared Rothstein
Senior Manager, Regulatory Affairs


In December 2020, the U.S. Environmental Protection Agency (EPA) released its proposed triennial updates to the Toxic Substances Control Act (TSCA) Fees Rule. SOCMA has responded to EPA’s proposed TSCA fee revisions, addressing major aspects of the proposal, incuding:

  • Supporting EPA’s proposed decision to not increase fees on new chemical submissions such as Pre-Manufacture Notices (PMNs) and exemptions.
  • Supporting EPA’s proposed exemptions (byproducts, impurities, research & development, de minimis volume, non-isolated intermediates) for EPA-initiated risk evaluations.
  • Supporting a volume-based fee allocation approach for to calculate risk evaluations fees to replace the current per capita method.
  • Recommending that the agency modify the criteria for risk evaluation exemption and cessation certifications to improve conformity and comprehensibility. 
  • Recommending that the agency provide a mechanism for companies to pay a fee to enter or re-enter the market for a High Priority chemical if they certified out of the risk evaluation, and recommending that EPA set up reimbursements for original payers.

SOCMA anticipates that EPA will finalize the TSCA fee updates by October 2021, and will be working to reinforce its recommendations to the agency while preparing new guidances for members on the fee requirements. For more information on the proposed fee revisions, please view SOCMA’s comments.

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