Tom Berger Quoted in Chemical Watch Article, "EPA Issues Final List of Companies Responsible for TSCA Risk Evaluation Fees"

Date: Sep 04, 2020

Keller and Heckman Partner Tom Berger was quoted in the Chemical Watch article, “EPA Issues Final List of Companies Responsible for TSCA Risk Evaluation Fees.” The article discusses how The U.S. Environmental Protection Agency (EPA) has released the final list of companies responsible for paying a share of the $1.35 million fee that comes with each of the next 20 TSCA risk evaluations for high-priority chemicals. The final list is similar to the interim tally released in August, with a few changes, including a handful of companies, both added and removed, as fee payers for the various substances. Modifications to the final list were based on a public comment period and self-identification window that ran from late January to June 15, 2020.

Mr. Berger noted that the smaller list "looks a lot like what one would expect." The EPA was flexible throughout this process, he said, recognizing the "shortcoming created by the absence of meaningful exemptions" from the fee obligations.

Manufacturers and importers on the list now have 120 days – until January 2, 2021 – to meet the payment due date.

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