Date: Mar 25, 2020
Keller and Heckman Partner Tom Berger was quoted in the Chemical Watch article, “EPA Plans TSCA Fee Exemptions for Imported Articles, Impurities.” The article discusses how EPA will not enforce self-identification requirements for certain high-priority chemical manufacturers or those who manufacture them only as impurities or byproducts to identify themselves for TSCA fee payments. EPA will exercise its enforcement discretion for manufacturers that import a high-priority substance in an article, produce one as a byproduct, and produce or import one as an impurity. Mr. Berger noted that EPA is taking prudent, appropriate and helpful steps.
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