July 5, 2020

Volume X, Number 187

July 03, 2020

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EPA Extends Deadline for Manufacturers and Importers Under the TSCA Fees Rule to June 15, 2020

EPA recently announced that the comment period and deadline for self-reporting under the TSCA Fees Rule has now been extended to June 15, 2020.

Under the TSCA Fees Rule, EPA is authorized to collect fees from manufacturers of chemicals identified by EPA for risk evaluations. As a result, EPA is requiring all manufacturers (which includes importers) of the 20 chemicals currently slated for risk evaluations to self-report to EPA so it can assess fees to these manufacturers on a pro-rata basis.  

As we reported earlier this month, EPA subsequently exempted certain importers of articles and manufacturers of by-products and impurities from this reporting requirement. Entities falling under the exemption that were on EPA’s Preliminary List or that had already self-identified had until May 27, 2020 to inform EPA they were exempt to avoid being placed on the Final List.

With this extension, subject manufacturers and exempt parties now have until June 15 to complete their certifications.

© 2020 Foley & Lardner LLPNational Law Review, Volume X, Number 149


About this Author

Special Counsel

Maria (Mia) Lombardi is special counsel and an environmental lawyer with Foley & Lardner LLP. She is a member of the firm’s Business Law Department and Environmental Practice. Mia is admitted to practice in Ohio; not admitted in Wisconsin.

Mia has extensive experience in a range of environmental matters with a focus on regulatory compliance, transactions, remediation and product stewardship. She has counseled on regulatory requirements and non-compliances under state and federal waste, wastewater, drinking water and air regulations as well as implementation of...