Submitting feedback vector

The American Cleaning Institute (ACI) submitted comments to the U.S. Environmental Protection Agency (EPA)’s Fees for the Administration of the Toxic Substances Control Act (TSCA).

In comments sent to the EPA, ACI recommends the following amendments be made to the proposed TSCA fee rule:

• A realistic, updated timeline for when evaluations will be completed for both new and existing chemical evaluations, in association with the current TSCA fees

• An extended explanation should be provided for what benefits will be seen by the regulated community if the proposed fee increases become final

• EPA should provide a more predictable allocation methodology

• EPA should provide an explanation for how these increased fees will address environmental justice concerns

• The rule should provide for the ability of a manufacturer to receive a full fee refund if submissions are not reviewed and decisions are not made in a timely manner

• EPA should include importers in its byproduct exemption to be consistent with other exemptions

• The R&D exemptions should align across all TSCA rules with the standard definitions in the 40 CFR 720.36 and 720.78


“While ACI and our members continue to advocate for the Office of Pollution Prevention and Toxics to receive federal appropriations commensurate with achieving fundamental improvements to the TSCA program, we are nonetheless concerned about the substantial increase of TSCA administration fees imposed on manufacturers, formulators and distributors” wrote Darius Stanton, ACI Director, Regulatory Science.

“The regulated community should not be asked to pay more in fees without a specific assurance that there will be measurable benefits eventually observed. To date, EPA has been missing deadlines both for new chemical approvals and for risk evaluations on existing chemicals. This process has hampered the manufacturing sector’s ability to put safer, more sustainable chemistries on the market for consumers.”

Read the association’s complete comments here.