Manufacturer and Importer Liability under the TSCA Fees Rule for EPA-Initiated Risk Evaluations: An Opaque and Evolving Story

Read the full post at JD Supra.

We understand that invoices have been transmitted to at least certain manufacturers of the 20 high-priority chemical substances for risk evaluation subject to fee payments. In the invoices that we are aware of, EPA is assessing one-third of the fee owed at this time, with a due date of January 2, 2021; it has not stated the due date(s) for the remainder of the fee. Under the Fees Rule, the entire fee is due by January 2, 2021. While we believe that the deferral of the assessment of two-thirds of the fee will be a welcomed development for most fee payers, especially in light of the COVID-19 health crisis, greater transparency in how and when EPA is invoicing for the fees would also be welcomed. We are aware of no general announcement by EPA of this modified process.

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