April 20, 2021

Volume XI, Number 110

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April 20, 2021

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April 19, 2021

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EPA Extends Comment Period For Proposed Updates To TSCA Fees Rule

EPA announced that it is extending the public comment period on proposed updates to the Toxic Substances Control Act (TSCA) Fees Rule to give stakeholders more time to review and comment. The current comment period was set to close on February 25, 2021. Comments are now due on March 27, 2021. Information on the proposed updates is available in the Bergeson & Campbell, P.C. (B&C®) December 30, 2020, memorandum, “EPA Intends Proposed Rule to Increase Flexibility and Reduce Burdens under TSCA Fees Program.”

On February 18, 2021, EPA held a virtual public meeting on the TSCA Fees Rule, allowing stakeholders to provide input on the proposed rulemaking. One of the main concerns by industry stakeholders was related to fees collection under TSCA Section 4. Stakeholders reported that EPA should not collect such fees under Section 4 because the same fees are collected under Section 5. The Alliance for Automotive Innovation proposed instead a tiered fees structure, given that the rule as proposed includes downstream user fees, which would double fees within the supply chain.

On the other hand, representatives from the Environmental Defense Fund (EDF) expressed opposition to the exemptions outlined in the proposed rule and criticized EPA for relying on voluntary information requests.

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©2021 Bergeson & Campbell, P.C.National Law Review, Volume XI, Number 64
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About this Author

Lynn Bergeson, Campbell PC, Toxic Substances Control Act Attorney, federal insecticide lawyer, industrial biotechnology legal counsel, Food Drug Administration law
Managing Partner

Lynn L. Bergeson has earned an international reputation for her deep and expansive understanding of the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), European Union Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), and especially how these regulatory programs pertain to nanotechnology, industrial biotechnology, synthetic biology, and other emerging transformative technologies. Her knowledge of and involvement in the policy process allows her to develop client-focused strategies whether...

202-557-3801
Ligia Duarte Botelho Bergeson Campbell Manager
Manager

Ligia Duarte Botelho, M.A., Manager with B&C® Consortia Management, L.L.C. (BCCM), assists consortia in reaching and exceeding their institutional goals in policy advocacy, public outreach, product stewardship, and testing and compliance.  Ms. Botelho offers BCCM clients the significant experience she gained as manager of a national medical science research and policy consortium, with a demonstrated excellence in synthesizing and communicating effective advocacy messages in her work with academic, global health, and science institutions.  Ms. Botelho holds a Master’s degree...

202-833-6583
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