EPA shares revised guidelines for making changes to the TSCA Inventory

March 01, 2022

Beginning April 26, 2022, EPA is requiring registrants to submit a premanufacture notice (PMN) or exemption notice should they wish to make changes to the specific chemical identity of a chemical substance currently listed on the TSCA inventory.


Since its establishment in July of 1980, EPA has maintained the same guidelines for making corrections to chemicals listed on the TSCA Inventory. Recognizing that chemicals could have been incorrectly reported, the Agency published a corresponding guidance in 1980 for registrants to submit inventory corrections. However, when doing so, the Agency did not establish a time frame for these submissions.

Changing guidelines

After 40 years of following the same guidelines, the EPA has determined the correction request process has unintentionally made it possible for registrants to avoid PMN or exemption notice submissions for new chemicals when they should be doing so. From now until April 26, 2022, EPA will be phasing out the use of its correction submission process. Any corrections that need to be made to the specific chemical identity of a chemical substance on the Inventory after April 26th may be subject to a PMN or exemption notice if the chemical substance is not currently listed on the Inventory.

How can TSG help?

Do you need assistance completing a PMN or exemption notice? Have questions concerning EPA’s revised guidelines?

TSG’s TSCA specialist, Dr. Saadia Eltayeb, would be happy to speak with you.

Get in touch: [email protected]

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