New Requirements for Submitting Premanufacturing Notices, TSCA Section 5 Notices and Supporting Documents Will Soon Take Effect

The US EPA is transitioning to new electronic reporting formats and these changes take place starting in January 2016.

Under these new electronic reporting regulations, users are required to use the Central Data Exchange (CDX) for electronic submission of Premanufacture Notices (PMNs),  TSCA section 5 Notices and Supporting Documents to the Agency. These changes were communicated in a direct final rule issued on July 20th, 2015 and take effect starting January 19th, 2016.

Changes include “new methods for accessing the e-PMN software, new procedures for completing the electronic-PMN (e-PMN) form, changes to the CDX registration process, adds the requirement to submit “bona fide intents to manufacture” electronically, and changes to the procedure for notifying EPA of any new manufacturing site of a chemical substance for which an exemption was granted by EPA.

This action is intended to further streamline and reduce the administrative costs and burdens of TSCA section 5 notifications for both industry and EPA.”

In anticipation of these new electronic reporting requirements, the EPA hosted a series of webinars in August and September to familiarize users with the new software and requirements.  To review these courses, see the US EPA webinar reviews here.

As these new requirements take effect January 19th, 2016 the EPA is strongly encouraging submitters to register as soon as possible for CDX and the updated e-PMN software (thin client) to avoid any delays in submissions.

For further information on these changes, including if this action applies to you, see here.