Export of PCBs for Disposal

The importation of PCBs is manufacturing for purposes of TSCA and the PCB regulations. Therefore, the statutory prohibition on manufacture of PCBs absent an authorization or exemption applies equally to the importation of PCBs. Additionally, no person may import PCBs or PCB Items for disposal without an exemption. 

Similarly, no person may export PCBs or PCB Items for disposal with the exception of PCBs and PCB Items at concentrations less than 50 ppm, which 

Robert E. Fabricant, Interpretive Statement on Change in Ownership of Real Property Contaminated with PCBs (Aug. 14, 2003), available at http //www.epa.gov/epawaste/ hazard/tsd/pcbs/pubs/distincom.pdf. 

Manufacture is defined as meaning to produce, manufacture, or import into the customs territory of the United States. 40 C.F.R. 761.3. 

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G. Import and Export of PCBs for Disposal H. Notification of PCB Waste Activity, Manifests, Records, 376... 

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