Bergeson & Campbell, P.C. (B&C®) is a Washington, D.C. law firm providing chemical and chemical product stakeholders unparalleled experience, judgment, and excellence in matters relating to TSCA, and other global chemical management programs.

By Christopher R. Blunck
 
On November 25, 2020, the U.S. Environmental Protection Agency (EPA) released updates to the interim final list of manufacturers and importers subject to fees for the next 20 chemicals undergoing risk evaluation under Section 6(b) of the Toxic Substances Control Act.  According to EPA, “[t]he updated list includes additional manufacturers not identified on the final list of companies and removes manufacturers that self-identified in error or imported the chemical solely for the purpose of research and development.”  EPA stated it is committed to ensuring this list is accurate and that it planned to use this updated list to begin invoicing for fees in early November.  EPA also stated that due to the public health emergency, EPA is exploring options for payment flexibilities.
 
On September 4, 2020, EPA published a Federal Register notice announcing the final lists identifying the manufacturers (including importers) of the 20 chemical substances that have been designated as high-priority substances for risk evaluation and for which fees will be charged.  85 Fed. Reg. 55283.
 
More information is available in our September 4, 2020, memorandum, “EPA Publishes Final Scope Documents and List of Manufacturers Subject to Fees for Risk Evaluations of High-Priority Chemicals.”