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TSCA Inventory Reset Rule


Last week EPA issued the pre-publication version of its much-anticipated final TSCA Inventory re-set rule. Because the new regulation affects every company that manufactures, imports, or processes chemical substances in the U.S., a wide swath of industry will be impacted by the rule including almost every company in the manufacturing sector. The main purpose of the Inventory Reset rule is to provide EPA with a clear picture of all chemical substances that are active in commerce in the U.S. To accomplish this, the rule establishes both “retrospective” and “forward-looking” reporting requirements for manufacturers, importers and processors of chemical substances that are listed on the TSCA Inventory. These designations are key—a substance designated as inactive can no longer be manufactured or processed in the U.S. until the certain reporting requirements are satisfied. Click here for more information on how your company may be affected by the rule and to identify specific steps you can take to minimize disruption caused by the rule.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Warren Lehrenbaum
Partner – Washington, D.C.
Phone: +1 202.624.2755

Preetha Chakrabarti
Counsel – New York
Phone: +1 212.895.4327

Crowell & Moring LLP is an international law firm with approximately 550 lawyers representing clients in litigation and arbitration, regulatory and policy, and transactional matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation, as well as its ongoing commitment to pro bono service and diversity, equity and inclusion. The firm has offices in Brussels, Doha, London, Los Angeles, New York, Orange County, San Francisco, Shanghai, and Washington, D.C.

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