On July 23, 2026, the U.S. Environmental Protection Agency (EPA) published proposed Significant New Use Rules (SNURs) under Section 5 of the Toxic Substances Control Act (TSCA)…
On July 23, 2026, the U.S. Environmental Protection Agency (EPA) published proposed Significant New Use Rules (SNURs) under Section 5 of the Toxic Substances Control Act (TSCA) for certain chemical substances that were previously the subject of premanufacture notices. The proposal marks another step in EPA's ongoing effort to scrutinize chemicals as they move from initial review into broader commercial activity, and it carries direct compliance implications for manufacturers, importers, and processors operating in affected supply chains.
Under the proposed rules, any person who intends to manufacture (including import) or process one of the covered chemical substances for a use designated by EPA as a significant new use would be required to notify the agency at least 90 days before commencing that activity. This pre-activity notification obligation is a hallmark of the SNUR framework and is intended to give EPA an opportunity to evaluate potential risks associated with the new use before commercial activity begins. Companies that fail to submit a timely and complete notification could face enforcement exposure, including civil penalties and potential restrictions on continued activity involving the substance.
The practical impact of the proposal will depend on how broadly the designated significant new uses are defined in the final rule and on the specific chemical substances covered. Businesses should promptly review their product portfolios, raw material inputs, and downstream applications to determine whether any of the listed substances are present in their operations. Where a covered substance is identified, companies should assess whether current or contemplated activities could fall within a designated significant new use, and they should evaluate internal processes for tracking chemical inventories and preparing TSCA Section 5 submissions.
EPA is accepting public comments on the proposed SNURs on or before August 24, 2026. This comment window offers a meaningful, but time-limited, opportunity for stakeholders to provide technical data, use-pattern information, and policy input that could influence the scope and clarity of the final rules. Industry associations and individual companies may wish to coordinate their submissions to ensure that operational realities are reflected in the record.
This article is provided for general informational purposes only and does not constitute legal advice. Clients affected by the proposed SNURs should seek tailored guidance regarding their specific circumstances.