Schedule a demo
Schedule a Demo
Schedule a Demo
Schedule a Demo
GoCompliance Blog

EPA Releases New Resources for New Chemical Notices Under TSCA

by Georgie Whitehouse on Jul 14, 2025 4:05:16 PM

On April 25, 2025, the U.S. Environmental Protection Agency (EPA) released new guidance and technical support materials to help companies comply with the updated requirements for submitting new chemical notices under the Toxic Substances Control Act (TSCA).

These updates follow the final rule issued in December 2024 and aim to clarify data expectations while the EPA prepares to update its Central Data Exchange (CDX) system.

What Changed?

Clarified Data Expectations

The December 2024 final rule clarified what information must be included in pre-manufacture notices (PMNs), significant new use notices (SNUNs), and other TSCA Section 5 submissions. Companies are now expected to include all information that is “known or reasonably ascertainable.”


CDX System Updates Pending

Although the rule is in effect, updates to EPA’s CDX portal—the system used to submit notices—have not yet been released.


Temporary Workaround Available

In the interim, EPA has published detailed instructions for how to comply with the new requirements using the current CDX interface. These instructions include guidance on documenting “not known or reasonably ascertainable” (NKRA) data elements.


Future Roll-Out Planned

The EPA will conduct stakeholder engagement before launching the enhanced CDX system. Once live, the current interim process will be retired.


Key Resources from the EPA

The EPA’s new technical support materials include:

  • Step-by-step instructions for submitting complete TSCA notices through the current CDX system

  • Tables outlining data requirements and how to determine what is reasonably ascertainable

  • Examples and best practices to help companies provide thorough and accurate information

Why This Matters

  • Avoid Submission Delays
    Incomplete notices may be rejected or delayed, leading to longer review timelines and increased regulatory risk.

  • Maintain Audit-Ready Documentation
    Clearly documenting how each data point was collected—or why it is not reasonably ascertainable—helps ensure transparency and regulatory defensibility.

  • Prepare for System Changes
    Companies that begin adapting now will be better positioned when the CDX updates are rolled out.

GoCompliance Recommendations 

  • Review Data Standards: Familiarize yourself with the updated TSCA Section 5 requirements now.

  • Update Internal Processes: Adjust SOPs to reflect the new expectations, especially around “reasonably ascertainable” information.

  • Train Compliance Teams: Ensure everyone involved in TSCA submissions understands the new documentation practices.

  • Monitor CDX Developments: Track EPA communications for updates about the rollout of the enhanced system.

  • Keep Thorough Records: Maintain clear documentation to support any NKRA determinations.

Final Thoughts

EPA’s new guidance offers companies a valuable opportunity to improve the quality and defensibility of TSCA submissions. While CDX system enhancements are still on the horizon, the EPA’s interim support resources provide the tools needed to comply with the new rule today.

GoCompliance is closely monitoring these changes. If your team needs assistance adapting to the updated requirements or documenting compliance processes, our experts can help you stay prepared and audit-ready.

Contact us to learn more about how GoCompliance supports TSCA readiness.

 
Topics: TSCA

No Comments Yet

Let us know what you think

See all