From Inside TSCA

Landmark Appellate Ruling Could Limit TSCA Rules On ‘Dead’ Chemical Uses

April 2, 2024
The landmark appellate ruling overturning a set of TSCA compliance orders could render unlawful EPA’s long-standing practice of crafting significant new use rules (SNURs) to block resumption of “dead” uses for existing chemicals -- just as the agency is using that approach for PFAS and other “high-priority” substances, environmental and industry attorneys say. “We need to see how the decision is applied but we should be concerned about its implications for the use of the SNUR authority generally for existing...


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