Proactively addressing changes to TSCA exemptions

28 April 2021

In a recent article in Chemical Watch, Ramboll experts Ashish Deshmukh, Gavin Thompson and David Liu address the issues importers of articles into the US are facing related to the Significant New Use Rule (SNUR) for long-chain perfluoroalkyl carboxylates (LCPFACs) in surface coatings following recent changes.

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Ashish Deshmukh, PhD

Senior Managing Consultant
T: +1 614 408 0914
M: +1 614 323 8407
Gavin Thompson

Gavin P. Thompson

PhD, Principal Consultant
T: +1 602 734 7704
david liss

David K. Liu

PhD, Principal
T: +1 949 798 3663

LCPFACs have long been applied to surface coatings of articles due to their concurrent hydrophobic and oleophobic properties, but their bioaccumulative and persistent properties have frequently made them a source of concern for USEPA. Recent regulatory changes are expected to impact imported fiber, yarn and apparel; carpets; computers and other electronic products; appliances; automotive parts; paper goods; and construction materials.

In the article How are imported products affected by recent changes to exemptions for chemicals in articles under TSCA?, our experts break down the history of regulations related to LCPFACs, what surface coatings and articles may be impacted, and how the current changes may affect importers. They outline steps importers can take to understand and monitor liabilities, and ways to reach and maintain compliance. The authors also look forward to possible further changes to the regulation, including expanding policy to include whole articles and not only surface coatings. 

READ THE FULL ARTICLE

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