On January 27, 2023, the US Environmental Protection Agency (EPA) proposed the implementation of the Significant New Use Rule (SNUR) for inactive PFAS substances listed under the Toxic Substances Control Act (TSCA).
After nearly a year of discussion and deliberation, this control measure was finally officially implemented on January 8, 2024!
1. Inactive substances
The inactive substances in the TSCA directory refer to chemical substances that have not been produced, imported, or processed in the United States since June 21, 2006.
In general, such chemicals do not require a complete EPA assessment and risk resolution to resume production, import, and processing trade activities within the United States.
With the introduction of the latest control policies, the process for resuming production of inactive PFAS substances within the United States will undergo changes.
2. Background of measures introduced
The EPA considers that if inactive PFAS substances are allowed to resume production and other activities without a complete assessment and risk resolution, it will inevitably cause harm to human health and the environment.
Therefore, the EPA has decided that such substances must undergo a Significant New Use Declaration (SNUN) before resuming production and other activities. The declarant needs to submit information on their use, exposure, and release within the United States to the EPA for evaluation, and determine whether they will pose uncontrollable risks to human health and the environment before use.
3. Which substances will face control measures
This control policy involves 329 inactive PFAS substances.
299 substances have been listed on the list, and companies can confirm them through information such as CAS numbers. But there are still 30 substances that are not clearly listed due to their involvement in CBI applications. If the material of the enterprise meets the following PFAS structure definitions, it is necessary to submit a novelty check confirmation to the EPA:
R - (CF2) - CF (R ') R', where both CF2 and CF are saturated carbon;
R-CF2OCF2-R ', where R and R' can be F, O, or saturated carbon;
CF3C (CF3) R'R '', where R 'and R' 'can be F or saturated carbon.
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Post time: Jan-12-2024
