US TSCA compliance for importers starts before customs entry, not after
EPA has refreshed its guidance for chemical importers. The core message for compliance teams: customs clearance is not the same as TSCA compliance. Before a chemical substance — on its own, in a mixture, or in some articles — enters US commerce, the importer needs to have checked TSCA Inventory listing and active/inactive status, any section 5 PMN or Significant New Use Rule, section 6 restrictions, Title VI formaldehyde requirements for composite wood, and the TSCA import certification. These checks belong in the import process, not after the goods arrive.
Published10 Sept 2026
EffectiveOngoing obligation; EPA import guidance refreshed September 2026. No fixed deadline — the checks belong before each shipment and customs entry.
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