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HCThe Honest Chemist
Logistics · 2 MIN READ

TSCA compliance basics for chemical importers

The Honest Chemist

If you import chemical substances into the United States, the Toxic Substances Control Act is your law. Not your supplier's, not your broker's — yours, as the importer. The good news: for mainstream industrial chemicals, TSCA compliance is a manageable, documentable routine. Here are the basics every importer should have straight.

This article is general information, not legal advice — for specific situations, involve qualified regulatory counsel.

The Inventory is the center of gravity

TSCA's core mechanism is the TSCA Inventory — the list of chemical substances that may be legally manufactured in or imported into the US for TSCA-covered uses. A substance is either on the Inventory ("existing") or it is not ("new"). Importing a new chemical substance without going through EPA's premanufacture notification (PMN) process is a serious violation.

When a distributor says a product is "TSCA-listed," they mean the substance appears on the Inventory and can be imported for industrial use in the ordinary way. Every commodity we list on this site shows its TSCA status right on the product page, next to CAS number and DOT data.

Certification at the border

Each shipment of a chemical substance requires a TSCA certification at entry:

  • Positive certification: the shipment complies with TSCA — the substances are on the Inventory or otherwise exempt.
  • Negative certification: the shipment is not subject to TSCA (typical for products regulated instead as pesticides, foods, drugs, or cosmetics under other statutes).

Your customs broker files this electronically, but the broker certifies on your information. The importer of record owns its accuracy.

What a clean compliance file looks like

For each imported product, you want to be able to produce:

  1. Exact substance identity — CAS number(s) for every component, not just a trade name. Mixtures need every component assessed.
  2. Inventory status for each component, checked against the current Inventory (including any active/inactive flag from the Inventory Reset rule).
  3. Applicable rules check: some listed substances carry Significant New Use Rules (SNURs), consent orders, or Section 6 restrictions that can affect your specific use.
  4. Supplier documentation: a TSCA compliance statement from the manufacturer, kept current.
  5. Records of the certifications made at entry.

Common pitfalls

  • Trade-name blindness: certifying a formulated product without knowing its full composition.
  • Assuming Europe's REACH work transfers: REACH registration says nothing about the US Inventory. The lists differ.
  • Ignoring SNURs: "on the Inventory" is not the end of the check.
  • Stale supplier statements: get compliance documentation refreshed periodically and whenever composition changes.

How we help

Every commodity chemical The Honest Chemist offers ships with a documented CAS identity and TSCA status, and our European producers provide the compliance statements your file needs. If you are evaluating a first import or moving a product from domestic to imported supply, contact us — we will make sure the regulatory groundwork is boring, which is exactly how compliance should feel.

Logistics