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On May 22, 2026, the U.S. Environmental Protection Agency (EPA) extended the reporting deadline for a rule under Section 8(d) of the Toxic Substances Control Act (TSCA) requiring manufacturers (including importers) of 16 chemicals to report data from unpublished health and safety studies to EPA. 91 Fed. Reg. 30222. The rule applies to manufacturers in the North American Industrial Classification System (NAICS) codes for chemical manufacturing (NAICS code 325) and petroleum refineries (NAICS code 324110) that are currently manufacturing (including importing) a listed chemical substance (or will do so during the chemical’s reporting period), or that have manufactured (including imported) or proposed to manufacture (including import) a listed chemical substance within the last ten years. EPA states that it is “considering a proposal to modify the scope of the TSCA section 8(d) Health and Safety Data Reporting Rule, including because of legitimate concerns raised regarding the scope of the rule and obligations arising thereunder and the ability of regulated parties to comply in a cost reasonable manner that provides information that is useful to the purposes underlying the rule.” EPA extended the reporting deadline from May 22, 2026, to May 21, 2027, for the chemicals covered under the rule:
- 4,4-Methylene bis(2-chloraniline);
- 4-tert-octylphenol(4-(1,1,3,3-Tetramethylbutyl)-phenol);
- Acetaldehyde;
- Acrylonitrile;
- Benzenamine;
- Benzene;
- Bisphenol A (BPA);
- Ethylbenzene;
- Naphthalene;
- Vinyl chloride;
- Styrene;
- Tribromomethane (bromoform);
- Triglycidyl isocyanurate;
- Hydrogen fluoride;
- N-(1,3-Dimethylbutyl)-N′-phenyl-p-phenylenediamine (6PPD); and
- 2-anilino-5-[(4-methylpentan-2-yl) amino]cyclohexa-2,5-diene-1,4-dione (6PPD-quinone).
More information on EPA’s December 13, 2024, final rule is available in our December 23, 2024, memorandum.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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