TSCA

TSCA

  • TSCA REPORTING HTS EFF. MARCH 2019

    QUESTION: Does anyone have a list of HTS numbers where TSCA reporting will be required starting 3/22/19 for regulated composite wood products (see CSMS 18-000727)? ============================== https://www.epa.gov/sites/production/files/2019-03/documents/final_hts_codes.pdf Tricia Stewart MOBIS Parts America, LLC International Logistics & Compliance 10550 Talbert Ave., 4th Floor Fountain Valley, CA 92708  office+ 1-949-468-1601 TStewart@mobisusa.com

  • SCA Title VI Wood Furniture Imports Blanket Certifications

    QUESTION: Regarding the supplier/vendor certification of compliant TSCA Title VI wooden furniture: 1. Is it acceptable to receive a dated and signed blanket TSCA Title VI certification (on supplier letterhead) from the supplier for their wooden furniture products shipped to the USA or is it necessary to require the supplier provide the TSCA Title VI […]

  • EPA formaldehyde regulations for composite wood products

    QUESTION: Regarding the regulations that take effect Jun 1, do they include 100% softwood and softwood products?  Or do the regulations pertain only to hardwood? ====================== ANSWERS: Here is a copy o the original Federal Register notice. It states: Does this action apply to me? You may be affected by this direct final rule if […]

  • TSCA TITLE VI COMPLIANCE

    QUESTION: When the Toxic Substance Control Act (TSCA Title VI) came out last year, importers could not report goods that were arriving U.S. ports before 12/12/17 as TSCA Title VI compliant.   The compliance date was pushed back by one year and the EPA was addressing issues with the trade. Does anyone know what changes […]

  • FDA AND TSCA

    QUESTION: If we import a research and development pharmaceutical compound into the US and transmit information to the FDA, can we automatically issue a TSCA negative certification or do we still need to analyze TSCA rules ========== Answers: My opinion is that these are 2 different government agencies that do not share information —- so […]

  • TSCA CERTIFICATE

    QUESTION:   Who can sign a TSCA certificate? Is this considered “doing Customs business”? *************** Answers: EPA expects that in most cases the TSCA import certification will be based upon actual knowledge of the importer. 40 C.F.R. § 707.20(c)(1)(iii).   TSCA Import certification statements may be preprinted, typed, or stamped on the invoice for each […]

  • ANSWERS TO QUESTION ON TSCA REPORTING

    Question: We are wrestling with conflicting information on what is the best practice for TSCA certification. First questions: Best case scenario would be to have the supplier provide a TSCA certificate when we are the IOR, for us to use with our entry filing. So the quandary is what to do if the supplier can […]

  • ANSWERS TO QUESTION ON TSCA REPORTING

    Question: We are wrestling with conflicting information on what is the best practice for TSCA certification. First questions: Best case scenario would be to have the supplier provide a TSCA certificate when we are the IOR, for us to use with our entry filing. So the quandary is what to do if the supplier can […]

  • TSCA FOR TOUCH UP PAINT

    Question: Our supplier is thinking of shipping a small tube of touch-up paint withcertain of their decorative outdoor items so that if the paint happens tochip off, they can touch it up. Does anyone foresee a problem with this?Would the paint get classed with the fountain, itself, under 8413.70? Or,would it have to be broken […]

  • TSCA AND FILING WITH PORT DIRECTOR

    Question: We import chemicals and are required to submit a positive TSCAcertification upon import.  Currently, with our broker approval, wecreate a blanket-type certificate by supplier listing each chemical for thatsupplier.   Our broker submits this certificate with each entry marking thechemical being imported. Per 19 CFR 12.121(a)(2), TSCA import certification statements are to befiled with the […]

  • PREMANUFACTURE TSCA NOTICE

    Questions; We have a product that has two chemical components that are clearly TSCAlisted. We do not believe a Premanufacture Notice was filed for thisparticular product. Should we file a PMN, even though the two components arealready listed on TSCA?