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More TSCA Obligations for Article Importers About PFAS

Tuesday, June 29, 2021 Do any of the articles, or article components, that your company imports contain PFAS? If so, your company may become subject to extensive reporting requirements proposed by EPA under the Toxic Substances Control Act (TSCA). The proposal was published on June 28, 86 Fed. Reg. 33926. It would establish a new Part 705 of 40 C.F.R., “Reporting and Recordkeeping Requirements for Certain Per- and Polyfluoroalkyl Substances.” Reports would likely be due in the second half of 2023. Comments on the proposed rule are due August 27, 2021. EPA notes, however, that if stakeholders submit comments by July 28, OMB will be able to consider them as it evaluates the paperwork burdens of the proposed rule.

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