Additional TSCA Requirements Applicable to Importers

Because the term manufacture in defined in TSCA to include import, anyone who imports chemical substances is subject to all the requirements of TSCA. Brief summaries ° of those requirements, which are more fully discussed in other sections of this book, are set forth below. Prior to importation, the importer should ascertain which of these requirements apply to the product to be imported and put in place procedures or systems to facilitate compliance. This is especially important for importers that do not typically deal with TSCA. While most of these requirements will arise upon or after importation, be aware that there may be 4 or 8 rules which require notification to EPA prior to, or on the date of, importation of 

http //iaspub.epa.gov/sor internet/registry/substreg/home/overview/home.do. 

Under 4, EPA has the authority to require importers to conduct testing on the health and environmental effects of chemical substances and mixtures. 

Test rules continue for a period of five years from the date the data from all required tests have been submitted or an amoimt of time equal to that which was required to develop the test data, whichever is longer. In terms of conducting required testing, importers are treated the same as domestic manufacturers. 

Section 8 authorizes EPA to require importers to keep certain records and to report certain information to the EPA. The relevant sections are  

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