Chemical Compliance

Questions and answers about Chemical Compliance

  • Classification of Chemicals

    QUESTION: Can the membership share work-instruction or RASI matrix or any other documentation on classification of Chemical products? =========== Answer: While not specifically a work instruction or matrix, I have provided training on Chemical Classification a couple of times for the membership.  I did a webinar in the spring and just presented at the ICPA […]


    QUESTION: What is the best ACE report to identify imported chemicals to comply with TSCA Chemical Data Reporting (CDR) for the past 4 years, that is due on November 30, 2020? I manage multiple customs brokers and IOR numbers, so it is troublesome to obtain detailed reports from brokers. Some of them had their POA […]


    Question: As an importer of chemical samples, we want to be 100% compliant with all requirements under DOT/IMDG/IATA/OSHA, etc. and the new GHS label initiative. To effectively do that, our product compliance team conducts an extensive review which includes an evaluation of supplier labels, often resulting in several days of email dialogue.  Due to this […]


    Question: I am hoping the membership can shed some light here. The new GL-4 which allows for exportation and reexportation of medicines to Crimea has a list of excluded medicines. This list includes ‘bioactive peptides’. I have found a definition of ‘bioactive peptides’ in the FAQ section of the Iran sanctions program. Can anyone tell […]


      Question:   I seek some guidance as an individual seeking to get a broker license but working in a sector I see as developing questionable trends, the Pharma/Biotech international supply chain, in regards to classification of new chemical entities, and synthesized compounds used in basic investigational drug development or research use only settings (RUO).  […]

  • Importing chemicals into Russia

      Question:   Does anyone in the membership have a guidance checklist they would be willing to share specific to importing chemicals into Russia?   We have a customer in Russia where they’ve begun to ask specific chemical compositions per the request of Russian Customs, yet our formulations are proprietary and we do not share […]


    Question: An overseas subsidiary creates a 1C350c chemical, entirely from ingredients acquired locally in that country. But they create it using U.S.-origin technology.1. This technology would require an export license, correct? Because it is used in the production of a 1C350 chemical. 2. If the above overseas subsidiary exports this chemical (produced entirely from local […]

  • California’s ATCM

    We received the attached notice from DHL regarding California’s Airborne Toxic Control Measure (ACTM). Can the membership clarify if the below requirement will include wood pallets?

  • Chemical Compliance Q&A 1

    QUESTION: I am hoping the membership could provide guidance or suggestions when dealing with chemical imports. 99% of our imports must be accompanied by a TSCA declaration when clearing Customs. For those imports on a PO, we have no worries, the imports happen like clock-work. Our problem is the import of samples of a chemical […]