Filing a Notice of Commencement (NOC) of Manufacture or Import under TSCA
A new chemical is added to the TSCA Inventory only after:
- the PMN review is complete or the review period has expired, and
- the PMN submitter has commenced nonexempt commercial manufacture.
Pursuant to section 5 of TSCA, the submitter of the PMN must provide a Notice of Commencement of Manufacture or Import Form (NOC) to EPA within 30 calendar days of the date the substance is first manufactured (which includes import) for nonexempt commercial purposes.
The chemical substance is considered to be on the TSCA Inventory and an existing chemical as soon as a complete NOC is received by EPA. Actual EPA processing of the NOC to complete the transaction takes about four weeks.
- Read EPA’s regulations relating to NOCs at 40 CFR 720.102.
Note for R&D substances: In the event there is an excess of an R&D substance, it may be used or sold after expiration of the PMN review period and does not require submission of an NOC. The substance will not be placed on the Inventory until an NOC is received; however, an NOC may not be submitted for the substance before commercial manufacture (non-R&D) begins.