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TSCA inventory
  • EPA must compile and keep current an Inventory of Chemical Substances in Commerce, which is a listing of chemical substances manufactured, imported, and processed for commercial purposes in the U.S.
  • Chemical substances on the TSCA Inventory include organics, inorganics, polymers, and chemical substances of unknown or variable composition, complex reaction products, and UVCBs.
  • EPA’s compilation of the public TSCA Inventory information is updated twice a year to include new and corrected TSCA Inventory chemical listings.

Section 8(b) of the Toxic Substances Control Act (TSCA) requires the Environmental Protection Agency (EPA) to compile and keep current an Inventory of Chemical Substances in Commerce (the TSCA Inventory), which is a published listing of chemical substances manufactured, imported, and processed for commercial purposes in the U.S. Also called “the Inventory,” it plays a central role in the regulation of most industrial chemicals in the U.S.

The initial reporting period by manufacturers, processors, and importers was January to May of 1978 for chemical substances that had been in commerce since January of 1975. The agency subsequently published the first Inventory in 1979. The TSCA Inventory is updated every six months and has continued to grow. It now lists more than 86,000 chemicals.

Since compiling the initial TSCA Inventory, TSCA section 5 requires that any person who proposes to manufacture (which includes import) a “new chemical,” i.e., a chemical not listed on the TSCA Inventory, must provide a premanufacture notice (PMN) or an exemption application to the agency at least 90 days prior to commencing manufacture of that chemical.

The agency regularly adds new chemical substances that have completed new chemical review requirements pursuant to TSCA section 5(a) and that have been manufactured or processed for non-exempt commercial purpose. EPA maintains the TSCA Inventory as the authoritative list of all the chemical substances reported to the agency for inclusion on the Inventory.

What chemicals are on and not on the TSCA Inventory?

TSCA defines a chemical substance as any organic or inorganic substance of a particular molecular identity, including any combination of these substances occurring in whole or in part as a result of a chemical reaction or occurring in nature, and any element or uncombined radical. Chemicals substances on the Inventory include:

  • Organics;
  • Inorganics;
  • Polymers; and
  • Chemical substances of unknown or variable composition, complex reaction products, and biological materials (UVCBs).

Chemical substances not on the Inventory are those with uses not regulated under TSCA. The use of these chemical substances is governed by other U.S. statutes on, for example:

  • Pesticides
  • Foods and food additives
  • Drugs
  • Cosmetics
  • Tobacco and tobacco products
  • Nuclear materials
  • Munitions

What does it mean for a chemical to be on the Inventory?

For purposes of regulation under TSCA, if a chemical is on the Inventory, the substance is considered an “existing” chemical substance in U.S. commerce. Any chemical that is not on the Inventory is considered a “new chemical substance.”

In addition to defining whether a specific substance is “new” or “existing,” the Inventory also contains “flags” for those existing chemical substances that are subject to manufacturing or use restrictions.

Background on completeness, accuracy, and legal standing

EPA’s compilation of the public TSCA Inventory information is updated twice a year to include new and corrected TSCA Inventory chemical listings, and it contains none of the chemical identities claimed as confidential. Thus, it is not as complete nor current as the information contained in EPA's TSCA Master Inventory File, which includes the chemical identities claimed as confidential and is updated continuously as new and corrected information is received by EPA.

Consequently, for the purposes of TSCA compliance, the TSCA Master Inventory File maintained by EPA's Office of Pollution Prevention and Toxics is the only complete and accurate source that can provide authoritative and conclusive information about which chemical substances are currently included in the TSCA Inventory.