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ARTICLE · 12 OCTOBER 2021

Article Importers May Face Another TSCA Obligation, This One Related To PFAS

Beveridge & Diamond, P.C.
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Do any of the articles, or article components, that your company imports contain PFAS.

United StatesEnvironment
Mark N. Duvall
Mark N. Duvall
Ryan J. Carra
Ryan J. Carra
Sarah A. Kettenmann
Sarah A. Kettenmann

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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