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IPC Encouraged as U.S. EPA Eases Up on TSCA Fees

Mar 26, 2020

As a result of IPC’s advocacy work, the U.S. EPA yesterday announced that it is exploring exemptions to the Toxic Substances Control Act (TSCA) “Fees Rule.”

The TSCA Fees Rule is designed to collect revenues to pay for risk evaluations of toxic substances. However, the EPA now says it will consider exemptions for manufacturers that import articles containing high-priority substances or that produce such substances as byproducts or impurities.

This regulatory relief has the potential to reduce long-term administrative and financial burdens for those three categories of manufacturers. If the change is approved, manufacturers who fall into these categories would no longer be required to self-identify under the TSCA Fees Rule.

In addition, the U.S. EPA is providing a No Action Assurance to these manufacturers with respect to the self-identification requirements. This means the EPA will exercise its discretion to not pursue enforcement action against such companies for violations of the self-identification reporting obligations.

IPC worked with the EPA to bring awareness to challenges facing member companies via meetings with senior officials and through comments to the public docket on both a request for a comment period as well as a collaboration with the Consumer Technology Association (CTA) and ITI to address concerns regarding the requirement to self-identify as an importer of an article containing a TSCA High-Priority Substance.

“IPC welcomes the news of these potential changes to the TSCA Fees Rule.” said John Mitchell, IPC president and CEO. “We appreciate that the EPA is responsive to our concerns about unnecessary financial obligations for some of our members.”

IPC will continue to engage with the EPA regarding the proposed changes and the process for executing these changes. We encourage all potentially affected companies to review the information provided by the EPA, and summarized in this IPC blog, to ensure they are doing their due diligence to comply with the TSCA Fees Rule.


IPC (www.IPC.org) is a global industry association based in Bannockburn, Ill., dedicated to the competitive excellence and financial success of its 5,800 member companies which represent all facets of the electronics industry, including design, printed board manufacturing, electronics assembly and test. As a member-driven organization and leading source for industry standards, training, market research and public policy advocacy, IPC supports programs to meet the needs of an estimated $2 trillion global electronics industry. IPC maintains additional offices in Washington, D.C.; Atlanta, Ga.; Miami, Fla.; Brussels, Belgium; Bangalore and New Delhi, India; Bangkok, Thailand; and Qingdao, Shanghai, Shenzhen, Chengdu, Suzhou and Beijing, China.

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