The Toxic Substances Control Act: Requirements For Importers

Importers of chemicals into the United States often find themselves in a precarious
position: under the Toxic Substances Control Act (TSCA), they are considered the equivalent of
chemical manufacturers and thus are subject to the most burdensome responsibilities under TSCA
The burden is compounded by the fact that TSCA is such a complex and demanding statute, and
few companies outside the U.S. are able to achieve sufficient expertise. Indeed, it is frequently
quite difficult for American companies to maintain high standards of compliance, given the ever-
changing requirements of the law. This paper provides a brief overview of the TSCA
requirements of interest to importers and examines their effect on chemical importers.