TSCA PBT - COMPLIANCE FOR ARTICLES

Passing the Frank R. Lautenberg Chemical Safety for the 21st Century Act in 2016, the US federal government has reformed the Toxic Substances Control Act (TSCA). Significant changes cover the assessment of chemicals for better protection of the public and the environment. As a result, the Environmental Protection Agency (EPA) has targeted some persistent, bioaccumulative, and toxic (PBT) substances in articles, per Section 6(h) of TSCA PBT.

How to Comply with TSCA PBT?

These amendments impact industries worldwide. To comply with the American laws, the manufacturers and importer will have to make sure that their supply chain is aware of these obligations and meets the TSCA requirements, on top of the California Prop. 65 obligations.

To do so, you are welcome to use the free Enviropass EPEC form. Ask your suppliers to fill in the Supplier’s information and TSCA tabs.

Enviropass is here to help you grasp the TSCA reform, verify the technical documentation with your supply chain and assess your products. We will audit the medium to high-risk suppliers and provide recommendations via a gap analysis.

TSCA Reform and In-scope Articles

A wide range of articles, or products, are potentially affected by these new restrictions or prohibitions. They include products placed into the American market with:

PVC plastics;
Cables;
Electronic equipment;
Rubber items;
Etc.

Medical devices, regulated under the US Food and Drug Administration (FDA), are excluded from the TSCA’s scope.

What are the Regulated the TSCA PBTs?

The federal Environmental Protection Agency (EPA) oversees of implementing the TSCA reform. EPA has targeted some substances that are considered persistent, bioaccumulative, and toxic (PBT) to the environment. These substances tend to remain a long time before being naturally destroyed. They also accumulate and are harmful to certain living beings:

PIP (3:1)
DecaBDE
PCTP
2,4,6-TTBP
HCBD

These substances are either restricted or merely prohibited from specific applications. Recordkeeping may also apply, with various effective dates.

More regulated substances are likely to be added to this list over the years, similarly to the EU REACH regulation. Furthermore, the EU RoHS and EU Halogen-free / POP also restrict some of these PBTs, such as DecaBDE and HCBD.

Want to know more about TSCA or other American regulations? Contact Enviropass!