On July 24, 2026, the U.S. Environmental Protection Agency (EPA) published a proposed rule in the Federal Register to seek public comments on Significant New Use Rules (SNURs) for 27 chemical substances under the framework of the Toxic Substances Control Act (TSCA). The comment deadline is August 24, 2026.
Chemical Substances Involved
The 27 chemical substances subject to control span multiple sectors including electronics, coatings, detergents, plastic additives, and photolithography materials:
|
Generic Name |
Principal Use |
Significant New Use |
|
Polysaccharide ether chloride |
Additive in consumer/commercial products |
• Manufacturing with amine nitrogen substitution degree exceeding the confidential percentage listed in the order; |
|
Heteroatom-substituted dihaloester |
Electrolyte additive |
• Manufacture or processing without personal protective equipment (PPE) when dermal exposure is possible; |
|
Rhamnolipids (various salts) |
Detergents, cleaners |
• Any manufacturing or processing method resulting in inhalation exposure; |
|
Carbon monocyclic alkyl amide (potential PBT chemical) |
Plastic additive |
• Use in consumer products; |
|
Bisphenol-epichlorohydrin type polymers (12 substances) |
Coatings for metal parts |
• Cationic amine nitrogen content exceeding 2% by weight; |
|
Polyoxyethylene acrylate |
Paints, coatings, inks |
• Failure to use PPE when dermal exposure is possible; |
|
Polyfluorinated sulfonium salts (potential PBT chemicals) |
Photolithography |
• Manufacture beyond the time limit specified in the order (9 months for P-25-98/99; 18 months for others) without submitting the required Tier I and Tier II testing; |
|
Aromatic sulfonium salts/iodonium salts (5 substances) (potential PBT chemicals) |
Photolithography/electronics industry |
• Domestic manufacture (importation only); |
Note: Most substances do not have publicly available CASRNs, as their chemical identities have been claimed as Confidential Business Information (CBI).
ChemRadar Insights
If this proposed rule is finalized, any enterprise that manufactures, imports, or processes any of these 27 chemical substances for a "significant new use" must submit a Significant New Use Notice (SNUN) to the EPA at least 90 days in advance. The affected enterprise may commence the relevant activity only after the EPA has completed its risk assessment and issued a determination. The primarily affected industries include chemical manufacturing (NAICS 325), petroleum refining (NAICS 324110), and related import trade. Since the specific identities of most chemical substances have been claimed as CBI, enterprises uncertain whether their products are subject to control may submit a "bona fide intent" application to the EPA to confirm the substance identity.
CIRS Services
- TSCA Inventory and confidential inventory searches
- Compliance strategies for existing substances listed on the TSCA Inventory
- Pre-Manufacture Notice (PMN) exemptions (substances under other regulatory jurisdictions, substances for R&D, low-volume substances, polymers, etc.)
- Pre-Manufacture Notices (PMNs)
- Significant New Use Notices (SNUNs)

