The Toxic Substances Control Act (TSCA) requires EPA to designate chemical substances on the TSCA Chemical Substance Inventory as either "active" or "inactive" in U.S. commerce.
On February 20, 2019, US EPA published the final "reset" TSCA Inventory, which triggered a 90-day grace period when manufactures (including importers) and processors must make final verification that their products contain only "active" substances. No amount of "inactive" substances will be permitted for manufacture, importation, processing or commercialization as of that date.
Any manufacturer, importer or processor who discovers that a product contains an "inactive" substance must notify EPA to re-classify that substance as "active" prior to May 20, 2019, or cease commercialization of products containing that substance until such notification to EPA has occurred. After this grace period closes, "inactive" substances become ineligible for commercialization in the US. Violators will risk substantial penalty.
Trinity Consultants offers comprehensive assistance with TSCA chemical management compliance, and is ready to assist with preparing and submitting notices to EPA that are needed to initiate EPA's process of changing an "inactive" designation to "active".