How to File a Notice of Commencement (NOC)
A new chemical is added to the TSCA Inventory after the PMN review period has completed/expired and the PMN submitter has commenced nonexempt commercial manufacture. The submitter of the PMN must provide a Notice of Commencement (NOC) of Manufacture or Import Form to EPA within 30 calendar days of the date the substance is first manufactured or imported 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.
If you submit a PMN to EPA after the effective date of the electronic-PMN ("e-PMN") final rule (75 FR 773) (PDF) (18 pp, 110K, about PDF), you must use the e-PMN software to submit your NOC to EPA. During the first year following the effective date of the final rule, Notice of Commencement submissions will be permitted via Central Data Exchange (CDX), optical disc or paper. One year after the rule's effective date, i.e., as of April 6, 2010, paper submissions will not be accepted. Two years after the final rule's effective date, i.e., as of April 6, 2012, all submissions will be required to be submitted electronically via CDX. Refer to www.epa.gov/cdx, the CDX Registration Guide (PDF) (44 pp, 8.6MB, about PDF), or the CDX Helpful Hints (PDF) (10 pp, 41K, about PDF) for directions on how to register and submit notices via CDX.
If you submitted a PMN prior to the effective date of the e-PMN final rule, April 6, 2010, you may use the e-PMN software to prepare your NOC; however, it must be printed and mailed as hard copy to the Agency. This is necessary because although the notices received after implementation of the new system will be entered into the newly created EPA database, notices submitted before promulgation of this rule will only exist in EPA's paper filing system.
Excess R&D substance may be used or sold after expiration of the PMN review period and does not require submission of a NOC. The substance will not be placed on the Inventory until an NOC is received; however, a NOC may not be submitted for the substance before commercial manufacture (non-R&D) begins.
Use of EPA Form 7710-56 became compulsory for NOCs filed after the effective date of the amended regulations published March 29, 1995. (60 FR 16336-16351).
The NOC should be submitted to EPA at the following address if using U.S. mail:
Document Control Officer
TSCA Confidential Business Information Center, Mail Code 7407M
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
If using courier service, the form should be submitted to EPA at the following address:
Document control Officer
TSCA Confidential Business Information Center, Room 6428
EPA East Building
1201 Constitution Ave., N.W.
Washington, DC 20004-3302
Telephone: 202-564-8930 or 202-564-8940
Upon delivery of a NOC by courier services, EPA East Building guards will contact Confidential Business Information Center personnel who will meet couriers in the building lobby. Courier deliveries of NOCs are accepted only on non-holiday weekdays from 8 a.m. to 4 p.m.
Notice of Commencement of Manufacture or Import Form (PDF) (1 pp, 84K, about PDF) - This old NOC form may be used for PMNs with a Day 1 prior to April 6, 2010, but cannot be used for PMNs submitted on or after April 6, 2010.