Toxic Substances Control Act
End-to-end TSCA compliance - Inventory verification, CDR reporting, Section 6 risk evaluation tracking, SNUR review, and audit-ready documentation for U.S. market access.
TSCA Compliance at a Glance
What You Receive
Every engagement produces structured, audit-ready compliance documentation. No generic reports - everything is specific to your chemical portfolio and U.S. regulatory footprint.
Deliverables are structured for ongoing use - not just to satisfy a single audit cycle. Each record is maintained with traceability back to the underlying source data and supplier declarations.
TSCA Inventory status verification with CAS number documentation for every chemical substance in your products
CDR reporting preparation, production volume threshold analysis, and four-year cycle filing support
Section 6 risk evaluation tracking and impact assessment for substances present in your product portfolio
SNUR applicability review for new or changed substance uses in manufacturing or import activities
Supplier data collection aligned to EPA reporting requirements, including TSCA Section 8(a)(7) PFAS declarations
Compliance records and audit readiness documentation structured for EPA inspection requirements
Who It Applies To
TSCA obligations apply to manufacturers and importers of chemical substances and mixtures in the United States, as well as companies that process or distribute these substances commercially.
If your products contain chemical substances manufactured or imported into the U.S., TSCA requirements may apply to your operations - particularly around Inventory compliance, CDR reporting, and risk management rules under Section 6. Downstream users and distributors are frequently subject to conditions arising from EPA risk management actions following completed risk evaluations.
A persistent misconception is that TSCA applies only to chemical manufacturers. In practice, importers, formulators, and companies that process chemical substances for commercial purposes carry direct compliance obligations under the statute. Foreign manufacturers exporting to the U.S. are not exempt - their importer of record carries the obligation.
Key Requirements
Core TSCA obligations that manufacturers, importers, and processors must address to maintain compliance and support U.S. market access.
All chemical substances manufactured or imported commercially must be listed on the EPA TSCA Chemical Substance Inventory before entering U.S. commerce.
Substances not on the Inventory require a pre-manufacture notification (PMN) submitted to EPA before commercial production or import can begin.
Manufacturers and importers must report production volumes, use data, and exposure information to EPA every four years when quantities exceed the 25,000 lb threshold.
EPA evaluates high-priority substances for unreasonable risk under Section 6, with findings that may impose restrictions, conditions of use, or outright prohibitions affecting product lines.
SNURs can trigger notification requirements when there is a change in how a substance is used, requiring companies to monitor SNUR publications relevant to their operations and supply chains.
A one-time PFAS reporting requirement mandates disclosure of historical PFAS manufacture and import, covering substances manufactured or processed since January 1, 2011.
Where Companies Fall Short
The most common TSCA compliance failures are systematic and avoidable. These are the gaps we resolve as a standard part of every engagement.
Companies routinely fail to verify whether chemical substances in imported products appear on the TSCA Inventory - creating direct legal exposure for every shipment that enters U.S. commerce without verification.
CDR reporting obligations are triggered at 25,000 lbs per site per year. Without systematic volume tracking, manufacturers and importers miss filings and accumulate civil penalty exposure across multiple reporting cycles.
Most companies are not actively tracking EPA risk evaluations underway for substances in their products - leaving them unable to respond to regulatory actions before restrictions become binding conditions of use.
Significant New Use Rules apply when use patterns for a substance change. Companies that do not monitor SNUR publications against their specific substance and application profile miss notification deadlines that trigger enforcement.
TSCA applies to importers as directly as it does to domestic manufacturers. Companies that assume TSCA obligations rest with their foreign suppliers are carrying unrecognized compliance liability on every import transaction.
EPA inspections require documented evidence of compliance - not assurances. Companies without structured records of Inventory status, CDR filings, and risk evaluation responses face penalties regardless of their actual compliance intent.
How The 3TGs Helps
Execution-focused TSCA support across every obligation area - built for manufacturers, importers, and downstream users operating in the U.S. market.
TSCA Inventory Verification - CAS number-level Inventory status checks for every chemical substance in your products, with structured records for ongoing reference and audit response.
CDR Reporting Support - Production volume threshold analysis, data compilation, and preparation of complete CDR submissions for each four-year reporting cycle.
Section 6 Risk Evaluation Tracking - Continuous monitoring of EPA risk evaluation status and impact assessment for high-priority substances present in your product portfolio.
SNUR Applicability Review - Systematic review of SNUR publications against your substance and use-case profile, with notification preparation where required by EPA action.
Supplier Data Collection - Structured supplier engagement campaigns aligned to EPA reporting requirements, including TSCA Section 8(a)(7) PFAS one-time reporting declarations.
Audit Readiness Documentation - Compliance records organized and formatted for EPA inspection, with clear evidence trails across every TSCA obligation area.
Ongoing Regulatory Monitoring - Proactive tracking of new EPA actions under TSCA - including risk management rules, SNUR publications, and Section 6 determinations - so your compliance posture stays current as the regulatory landscape evolves.
Ready to Resolve Your TSCA Exposure?
We verify your Inventory status, manage your reporting obligations, and track EPA actions that affect your products - so you are not caught unprepared when regulations tighten or enforcement escalates.
info@3tgs.org · UK +44 20 3996 3623 · US +1 209 286 0756
207 Regent Street, Third Floor, Suite 8, London W1B 3HH, United Kingdom