Objective
           IAEG has developed this overview of the TSCA Inventory Notification Rule 
            in order to assist the Aerospace & Defense industry. The TSCA Inventory is 
            an EPA list of ~85,000 chemicals (public and confidential) that, at one time, 
            were or are in commerce in the United States. The Inventory Notification 
            Rule is intended to identify those chemicals on the Inventory that are 
            “active” (i.e., that are still in commerce in the United States).
           This overview is intended to only address chemical substances already on 
            the EPA TSCA Inventory (Section 8b). Introduction of new chemicals is not 
            within the scope of this overview.
         
    ©2017 IAEG® all rights reserved
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    Table of Contents
        Content Description                                   Slide #
        I.   Roles, Responsibilities & Reporting Requirements                                4
        II.  Reporting Exemptions                                    7
        III. USEPA Central Data Exchange Reporting Requirements                             10
        IV. Confidential Business Information (CBI) Claims                            11
        V.   Potential Risks                                  13
        VI. Definitions                                       15
         
    ©2017 IAEG® all rights reserved                                                                              3
  Roles, Responsibilities & Reporting 
  Requirements
                                  Retrospective Reporting                        Forward Looking Reporting
      Manufacturers/importers of chemical substances in US                       After EPA issues the Final Inventory, manufacturers, 
       commerce between June 21, 2006 and June 21, 2016 must                       importers, and processors are strongly encouraged 
       review the Interim List of Active Substances.                               to review the Final Inventory to verify status of 
      If chemical substances are on the Interim List of Active                    chemical substances in US commerce.
       Substances or “otherwise exempt,” no further action is                            Note: Once a chemical substance is on the 
       required.                                                                          Final Inventory, it cannot be removed. Its 
      If chemical substances are not on the Interim List of Active                       designation (active/inactive) can only be 
       Substances, manufacturers and importers must submit a                              changed. Periodic Final Inventory reviews may 
       Notice of Activity (NOA) Form A to EPA by February 7, 2018.                        be needed.
      Within approximately 60 days after the manufacturer/importer 
       reporting ends, EPA will publish a Draft Inventory (est. April             90 days after publication of the Final Inventory, 
       2018).                                                                      manufacturers, importers, and processors may no 
      Processors of chemical substances in US commerce should                     longer use chemical substances designated as 
       review the Draft Inventory and may submit a NOA Form A by                   inactive; however, those that intend to manufacture, 
       October 5, 2018 to report chemicals that are not listed as                  import or process an inactive substance for non-
       active.                                                                     exempt commercial purposes must submit a NOA 
      Chemical substances that are not designated as active at the                Form B to EPA. This is required within 90 days of the 
       end of the processor reporting period will be identified as                 anticipated date of commercial activity.
       inactive by the EPA.
      EPA will update to a Final Inventory (active and inactive 
       chemical substances) “as soon as practicable” after the 
       processor reporting deadline (est. December 2018).
                        Note:  This U.S. regulation might require reporting by non-U.S. suppliers.
                        Note:  This U.S. regulation might require reporting by non-U.S. suppliers.
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     Reporting Sequence & Timeline
                              Retrospective reporting                                                         Forward Looking reporting
                              Retrospective reporting                                  EPA Review             Forward Looking reporting
                                                                                        EPA review
                                    NOA- Form A                                         EPA review                  NOA- Form B
                                    NOA- Form A                                                                     NOA- Form B
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   Roles, Responsibilities & Reporting 
   Requirements (conclusion)
     The NOA Form A and B information is to be included “to the extent that such 
       information is known to or reasonably ascertainable by that person.” The forms 
       must be certified under penalty of law by an “Authorized Official”, a person who is 
       in a position to sign the statement that appears in 40 CFR 710.29 (d)(5).  As 
       applicable (), NOA Form A and/or B information shall include:
                               Information                                 NOA Form A           NOA Form B
     Company Name                                                                                     
     Authorized Official                                                                              
     Technical Contact                                                                                
     Chemical Specific Information                                                                    
     Certification Statement, under penalty of law, by the                                            
     Authorized Official, as it appears in 40 CFR 710.29(d)(5)
     Intent to maintain/claim chemical identity is confidential                                       
     business information (CBI)
     Intended date of manufacture, import, or process for an                                           
     inactive chemical substance
  ©2017 IAEG® all rights reserved                                                                                6