If I import an unsponsored chemical that is subsequently included on a TSCA section 4 test rule, would I have any obligations under the rule?
Yes, you would be subject to the rule because importers are considered “manufacturers” under TSCA (see TSCA section 3(7)). You would be required to submit a letter of intent to test or an exemption application (see testing procedural rule at 40 CFR 790.45). If you submit an exemption application, you may be required to reimburse the entity that conducts the testing.
Related Questions
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- If I import an unsponsored chemical that is subsequently included on a TSCA section 4 test rule, would I have any obligations under the rule?
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