Introduction to U.S. TSCA Inventory
As is universally acknowledged, chemical substance inventory is an indispensible part of all kinds of chemical regulations in various countries and regions. Under the pioneering EU REACH, the European Inventory of Existing Commercial Chemical Substances (EINECS) is fundamental in determining the status of a substance, similar to the Chinese Chemical Inventory of Existing Chemical Substances (IECSC) and the Australian Inventory of Chemical Substances (AICS) as well as inventories in other parts of the world. Likewise, the TSCA Inventory under the U.S. Toxic Substances Control Act is such an essential tool that companies manufacturing or importing chemicals in the U.S. could hardly afford to neglect.
Put it simply, the U.S. TSCA Inventory is a list of existing chemical substances that are manufactured or processed in the United States, including over 84,000 chemical substances currently. There are two sections in the TSCA inventory: one goes public and the other is confidential. Only the public portion is available for search.
If a substance is on the public section of TSCA Inventory, it must be an existing substance. However, if not, it does not necessarily mean that the substance is a new one. It is likely that the substance may be included in the confidential section of the TSCA Inventory. Therefore, one can submit a Bona Fide Intent to the Environmental Protection Agency (EPA) for further search.
Manufacturers or importers shall fulfill corresponding responsibilities based on the searching result of a substance as either new or existing. For new substances, companies need to complete a Pre-Manufacture Notice if exemptions are not available. For substances containing significant new uses, a Significant New Use Notice is required for compliance. For existing substances, attention shall be paid to obligations in Chemical Data Reporting and Import Certification Statement etc.
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