SOCMA Issues Comments on OSTP Request for Information
on New National Strategy

March 16, 2026

Stacy Murphy
Deputy Chief Operations Officer/Security Officer
Office of Science and Technology Policy (OSTP)
Executive Office of the President
1650 Pennsylvania Avenue, NW
Washington, DC 20502

RE: Request for Information; National Strategic Plan for Advanced Manufacturing; NIST-2025-0004

Dear Ms. Murphy:

The Society of Chemical Manufacturers & Affiliates (SOCMA) appreciates the opportunity to provide comments on OSTP’s Request for Information (RFI) to inform development of the National Strategic Plan for Advanced Manufacturing.1 SOCMA appreciates OSTP’s commitment to advancing United States manufacturing competitiveness, reducing regulatory barriers, creating new jobs, and growing the economy nationwide.

SOCMA is the national trade association dedicated to the specialty and fine chemical industry. Founded in 1921, SOCMA represents a diverse membership of chemical companies who batch manufacture innovative chemistries used in a wide range of commercial, industrial, and consumer products. SOCMA maintains a strong record of member service through programs that maximize commercial opportunities, enhance regulatory and legal compliance, and promote industry stewardship. SOCMA’s members also implement ChemStewards®, an EHS&S performance improvement program that is a mandatory component of membership. Over 70% of SOCMA’s membership are small businesses.

Through this RFI, OSTP seeks input regarding Federal programs and activities to advance U.S. manufacturing competitiveness.2 OSTP is seeking input on several questions to provide guidance for Federal programs and activities, including information on “challenges and barriers that need to be addressed to ensure successful integration and widespread adoption of emerging technology in manufacturing”3 and how can “Federal agencies assist these companies in adopting advanced technologies.”4 SOCMA members wish to highlight a priority regulatory area that is in need of reform in order to grow American manufacturing and increase global competitiveness in the specialty chemical industry. That high priority area is the New Chemicals Review Program under the Toxic Substances Control Act (TSCA). Under the program, the U.S. Environmental Protection Agency (EPA) must review and approve new chemistries before they can be produced or imported into the United States. Further, chemical manufacturers must follow rigorous safety standards and other regulatory requirements in order to bring new chemistries into commerce.

SOCMA members and their customers manufacture, import, process, distribute, and use chemicals subject to TSCA, and so rely on EPA’s review process to bring new chemicals to market. Since innovation through new, improved, greener chemistries is the lifeblood of the specialty chemical industry, that review process must be transparent, efficient, predictable, and consistent with TSCA statutory authority for the industry to thrive.

Unfortunately, EPA’s existing process is unpredictable and inefficient, lacks transparency and consistency, and typically relies on overly conservative and unrealistic default assumptions about how a chemical will be used, instead of using real-world data provided by companies. New chemical reviews take significantly longer than they have in the past before TSCA was reformed by the Frank R. Lautenberg Chemical Safety for the 21st Century Act in 2016. Pre-manufacture notices (PMNs), which are new chemical applications, take multiple years for EPA to review and approve rather than the statutorily-required 90-day review period. And EPA’s approvals of new chemicals are 90% of the time conditioned upon stringent requirements such as workplace controls, restrictions on uses, limits on releases of the chemical, warnings to downstream users, and other restrictions. These restrictions are almost always included in EPA’s approvals of new chemicals due to concerns about potential uses of the chemical outside of the uses intended by the manufacturer who submitted the application and based on EPA’s own modeling data rather than real-world data.

As a result of these delays and restrictions, chemical manufacturers are discouraged from bringing safer and more innovative chemistries into the United States. Companies are forced to rely on older chemistries that may have lower performance and higher risk profiles than newer chemicals simply because EPA is unable to timely review new chemicals submissions consistent with using best available science. These regulatory impediments are a major obstacle for small and medium-sized specialty chemical manufacturing companies striving to adopt advanced technologies to increase efficiency and productivity. These delays make it very difficult for companies to make critical business decisions and plans for new products.

Left unaddressed, these issues will continue to stifle innovation for years to come and make it harder for specialty chemical manufacturers to adopt emerging technologies in manufacturing. Small businesses, which make up a substantial portion of SOCMA membership, disproportionately bear the impacts of these circumstances. These businesses are much less likely to invest vital resources into emerging technologies for advanced manufacturing where, once produced, new chemicals will languish trying to enter the market. The time lost navigating the regulatory quagmire will translate into diminished return on investment.

Rather than hamper this critical industry, the OSTP should encourage EPA to use its authority, consistent with the intent and purpose of TSCA, “in such a manner as not to impede unduly or create unnecessary economic barriers to technological innovation while fulfilling the primary purpose of [TSCA] to assure that such innovation and commerce in such chemical substances and mixtures do not present an unreasonable risk of injury to health or the environment.”6 SOCMA has advocated to both EPA and Congress for permanent reforms to the TSCA new chemicals review process for almost a decade. This issue remains a high priority for our membership. We are actively working to assist lawmakers in making such reforms, which are critical to ensuring that manufacturing remains in the U.S. and companies are not forced to innovate overseas due to unnecessary government red tape. SOCMA encourages OSTP to make a concerted effort to ease regulatory burdens on specialty chemical manufacturers as part of the National Strategic Plan for Advanced Manufacturing.

Thank you for the opportunity to provide these comments. Should you have any questions about these comments, please feel free to contact me at jklein@socma.org.

Respectfully submitted,
Jenn Klein
President and CEO
Society of Chemical Manufacturers & Affiliates (SOCMA)
1400 Crystal Drive, Suite 630
Arlington, VA 22202

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