What Is Not an Article
The draft compliance guide states that products such as paints, lubricants, and fire-fighting foam are not articles. A paint, however, would be considered as part of an article if applied to an article (
e.g., paint on a car is considered as part of an article but paint in a can is not an article under TSCA). Additionally, according to the draft guide, a lubricant applied to an article would be considered as part of an article. The draft compliance guide provides the following example:
A lubricant such as automotive grease would be considered part of an article when already included within an automobile’s engine. When automotive grease is purchased by a consumer at a car supply store to add to the automobile, that automotive grease would not be considered an article.
Monday, December 14, 2020
On December 10, 2020, the U.S. Environmental Protection Agency (EPA) announced the availability of a draft compliance guide that outlines which imported articles are covered by EPA’s July 2020 final significant new use rule (SNUR) that prohibits companies from manufacturing, importing, processing, or using certain long-chain per- and polyfluoroalkyl substances (PFAS) without prior EPA review and approval. The draft guide will be “the official compliance guide for imported articles that may contain long-chain perfluoroalkyl carboxylate chemical substances as part of a surface coating.” According to EPA, the draft guide provides additional clarity on what is meant by a “surface coating”; identifies which entities are regulated; describes the activities that are required or prohibited; and summarizes the notification requirements of the final SNUR. EPA intends to publish a notice in the
15 diciembre, 2020 – Crónica cronica.com.ec - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from cronica.com.ec Daily Mail and Mail on Sunday newspapers.
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