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PMN submission process
  • Submitters must use EPA’s CDX to submit TSCA section 5 notices and supporting documents electronically.
  • Six types of submitters may register with CDX.

Submitters must use the Environmental Protection Agency’s (EPA’s) Central Data Exchange (CDX) to submit Toxic Substances Control Act (TSCA) section 5 notices and supporting documents electronically.

Premanufacture notice (PMN) submissions must be made on EPA Form 7710-25 using the electronic PMN software (e-PMN). The e-PMN software enables manufacturers (including importers) of TSCA chemical substances to use the Internet, through EPA’s CDX, to submit TSCA section 5 notices to the EPA. These notices include, but are not limited to:

  • PMNs,
  • Bona Fide Notices,
  • Biotechnology Notices for genetically modified microorganisms;
  • Notices of Commencement of Manufacture (including Import) (NOCs), and
  • Support documents for section 5 notices (e.g., correspondence, requests for suspensions of the notice review period, amendments, letters of withdrawal, Transfer of Ownership, and test data).

The PMN form should also be used to submit:

  • Test Market Exemption applications (TMEAs),
  • Low Volume Exemption (LVE) notices and modifications,
  • Low Exposure / Low Release (LoREX) exemption notices and modifications, and
  • Mock PMNs.

In order to submit documents electronically to EPA, fill out PMN forms using the e-PMN software and submit through the CDX. To access CDX, pre-register with CDX and be approved by EPA. In order to access and use the new e-PMN software, all users must register with CDX for the Chemical Safety and Pesticide Programs (CSPP) program service.

Six types of submitters may register with CDX:

  • Primary Authorized Officials,
  • Primary Agents/Consultants,
  • Primary Supports,
  • Secondary Authorized Officials,
  • Secondary Agents/Consultants, and
  • Secondary Supports.

If there are technical issues or problems regarding the e-PMN software or CDX registration, contact the CDX Help Desk at helpdesk@epacdx.net or (888) 890-1995. International callers who wish to contact the Help Desk should call (970) 494-5500.

Note that the previous version of e-PMN software called eTSCA software can no longer be used to submit directly/electronically via CDX.