On June 20, 2023, the U.S. Environmental Protection Agency (EPA) proposed significant amendments to the existing rules related to the use of certain chemicals. A record of this proposal can be found published in the Federal Register.
Known as the Significant New Use Rules (SNURs), these amendments fall under the authority of the Toxic Substances Control Act (TSCA). It targets eighteen chemicals, all of which are derived from plastic waste recycling processes. The initiative has thus sparked considerable interest among legal professionals working in environmental law, corporate regulatory compliance, and similar fields.
The announcement of these rules follows close on the heels of premanufacture notifications (PMNs) submitted in 2015 and 2019, and these PMNs eventually led to the issuance of subsequent consent orders by the EPA. As outlined in the PMNs and consent orders, these chemicals include, among others, naphtha blends and… These orders took effect on August 25, 2022, under TSCA 5(e).
Further information and substantive content on the SNURs, TSCA, and the specifics of the chemicals in question can be found in a comprehensive review on the JD Supra website.
This proposal by the EPA is likely to have significant implications for the corporate world – especially those directly or indirectly involved in plastic recycling and related industries. Many companies may need to drastically reconsider their plastic waste disposal and recycling strategies, as compliance with these enhanced regulations can certainly pose challenges. These changes may also provide new realities for legal professionals, requiring them to adapt and become versed in these new areas of regulatory concern.