Guide

TSCA: Inventory, PMN, SNUR, CDR and the PFAS Reporting Rule

The Toxic Substances Control Act (TSCA), as amended by the 2016 Lautenberg Act, is the US federal chemicals law administered by EPA. Every chemical substance manufactured or imported into the US for non-exempt commercial use must either be on the TSCA Inventory or covered by a Section 5 Pre-Manufacture Notice (PMN) review. Significant New Use Rules (SNURs) lock in conditions agreed during PMN review. Section 8 imposes ongoing reporting — Chemical Data Reporting (CDR) every four years and, since 2023, a one-time Section 8(a)(7) PFAS reporting rule that has caught many manufacturers off-guard. This guide walks the structure and the practical readiness path.

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TSCA Inventory: active vs inactive, and the bona fide intent search

The TSCA Inventory is the master list of substances in US commerce. As of the 2017–2018 Inventory Reset, substances are designated 'active' or 'inactive'; manufacturing or importing an inactive substance requires a Notice of Activity (NOA) Form B before commencement. Confidential listings on the Inventory require a bona fide intent submission to confirm a substance is listed before relying on the listing. The recurring failure is assuming a substance is 'on the Inventory' from a supplier statement without verifying for the specific identity (CAS, structure) actually shipped.

Section 5 PMN, LVE/LoREX exemptions and the 90-day clock

A new chemical (not on the Inventory and not exempt) requires a PMN at least 90 days before manufacture/import. EPA performs a risk evaluation and may issue an Order under Section 5(e), require a SNUR under Section 5(a)(2), or accept the substance for Inventory listing. Reduced reporting routes include Low Volume Exemption (LVE, ≤10,000 kg/y), Low Release and Exposure Exemption (LoREX), Polymer Exemption (with strict structural criteria) and Test Marketing Exemption (TME). Each exemption has conditions; violation re-exposes the substance to full PMN.

SNUR — the lock-in that survives PMN

Significant New Use Rules under Section 5(a)(2) lock in the conditions of an EPA Section 5 review — uses, controls, exposure limits, hazard communication. Any use outside the SNUR-defined scope triggers a Significant New Use Notice (SNUN) 90 days before that use begins. SNURs apply to anyone who would manufacture, import or process for the new use, not just the original PMN submitter. This is the recurring trap for downstream users who acquire a SNUR-bound substance and use it outside the locked scope.

Section 8 Chemical Data Reporting (CDR) and PFAS Section 8(a)(7)

CDR under 40 CFR Part 711 requires four-yearly reporting (next: 2024 reporting on 2020–2023 data) of US manufacture and import quantities, processing and use information for substances at or above 25,000 lb/y per site (lower thresholds for PBT and Section 4/5/6 substances). The 2023 PFAS Section 8(a)(7) reporting rule under 40 CFR 705 imposes a one-time look-back to 2011 for any US manufacturer/importer of any PFAS in any quantity — an exceptionally broad sweep with no de minimis. EPA has extended the submission window into 2025–2026; the data ask is exhaustive.

A 60-day readiness path

Days 1–10: substance inventory with TSCA Inventory status verified per CAS, active/inactive flag, and exemption status. Days 11–25: SNUR audit — every SNUR-bound substance reconciled against current uses; SNUNs filed or use stopped where scope was exceeded. Days 26–40: CDR readiness — reporting-period quantities per site, processing and use codes, with the 2024 submission rehearsed. Days 41–55: PFAS Section 8(a)(7) data-pull from procurement, production and import records back to 2011; gaps flagged for supplier outreach. Days 56–60: bona fide intent submissions for any confidential Inventory listings relied upon without verification.

Where this lives in V5 Ultimate

The clauses above aren't theoretical — every one maps to a shipped module and an industry profile. Jump to the parts of the product that turn this guide into evidence on a Monday morning.

Modules that do the work

TSCA Inventory master

Active/inactive, SNUR scope, exemption status.

PMN / SNUN dossier control

90-day clock, conditions, downstream lock-in.

CDR / PFAS 8(a)(7) reporting

Thresholds tracked, look-back pre-populated.

Industries this hits hardest

Specialty & Industrial Chemicals

Frequently asked

Is the TSCA Inventory the same as the REACH registration list?

No. The TSCA Inventory is a US listing of substances in commerce; REACH registrations are EU dossiers with data attached. A substance can be on the TSCA Inventory without being REACH-registered and vice versa. The two regulators do not recognise each other's listings.

Do polymers need a PMN?

Most polymers qualify for the Polymer Exemption under 40 CFR 723.250 if they meet structural criteria (no reactive functional groups beyond defined limits, molecular weight thresholds, no fluorinated/perfluorinated monomers post-2010 amendment). Polymers failing the exemption need a PMN. EPA tightened the exemption for PFAS-containing polymers in recent rulemaking.

What's the difference between PMN and SNUN?

PMN is for a new substance not on the TSCA Inventory; SNUN is for an existing Inventory-listed substance that has a SNUR, when the planned use is outside the SNUR-defined scope. Both run a 90-day EPA review clock. Failing to file either before commencement is a Section 5 violation.

Are research and development chemicals exempt?

R&D chemicals are exempt from PMN under Section 5(h)(3) if they are manufactured/imported in small quantities solely for R&D and certain controls and recordkeeping are met. The exemption is not unlimited — scale-up to commercial production triggers full PMN.

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