Why TSCA SNUR Compliance Matters for Businesses

A SNUR can create risk when a company does not have clear visibility into the substances it manufactures, imports, processes, or uses in products and materials. The issue is not only whether a chemical substance exists in the supply chain. The key question is whether the company’s actual activity matches a use that EPA has designated as significant.

This is especially important for companies with complex supply chains. A TSCA SNUR obligation may be linked to a substance in a raw material, mixture, additive, coating, adhesive, component, intermediate, or imported chemical.

For a potential client, the practical concern is clear:

• Can we import this substance or product into the United States?
• Are we using a chemical substance in a way that requires EPA notification?
• Do we have enough supplier data to prove our compliance decision?
• Could a formulation, supplier, or customer-use change create a new SNUR obligation?
• Are we keeping the right records if EPA, customs, or customers ask for evidence?

Does TSCA SNUR Compliance Apply to Your Company?

TSCA SNUR compliance may apply if your company manufactures, imports, processes, distributes, or uses chemical substances covered by a Significant New Use Rule.

Latest TSCA SNUR Updates for 2026

EPA continued issuing proposed and final SNUR actions in 2026. This shows that companies should treat TSCA SNUR compliance as an active monitoring area, not a one-time check.

What Is a Significant New Use Notice?

A Significant New Use Notice, or SNUN, is the notice a company must submit to EPA before starting a designated significant new use. EPA states that a manufacturer or processor wishing to engage in a designated significant new use must submit a SNUN at least 90 days before engaging in that use.

EPA uses the SNUN review process to evaluate the intended use before it begins. This may include reviewing the substance identity, intended use, exposure conditions, worker protection measures, environmental release, disposal, and available health or environmental data.

EPA also explains that SNUN submissions are made electronically using the e-PMN form, and the submitter should identify the CFR citation of the SNUR and the specific significant new use being submitted.

What Activities Can Trigger a SNUR Obligation?

A SNUR obligation may be triggered when the actual business activity does not match the conditions allowed under the relevant rule. 40 CFR Part 721 is the main regulatory location for Significant New Use Rules and includes provisions covering notice requirements, import and export provisions, recordkeeping, workplace protection, hazard communication, industrial and commercial activity, disposal, and release to water.

Why Importers Face Higher SNUR Risk

Importers have a specific risk because TSCA defines manufacture to include import. EPA explains that the TSCA SNUN requirement applies to import of new uses of chemicals, meaning importers cannot treat SNUR compliance as only a domestic manufacturing issue.

This creates a practical challenge. Importers often rely on overseas suppliers for chemical identity, formulation details, use descriptions, and compliance declarations. If the supplier information is incomplete, the importer may not be able to confirm whether the substance is covered by a SNUR or whether the intended use requires EPA notification.

For importers, the question is not only:

“Is this chemical allowed?”

The more important question is:

“Is this chemical allowed for our specific import, processing, use, exposure condition, and downstream application without a SNUN?”

What Happens If a Company Misses a SNUR Obligation?

Missing a TSCA SNUR obligation can create business, operational, and regulatory risk. A company may face delayed product launches, blocked shipments, customer compliance concerns, incomplete import certification, enforcement exposure, or the need to stop a planned use until EPA review is complete.

SNUR compliance is therefore not only a legal task. It is a business continuity issue. If a company cannot confirm whether a substance or intended use is covered, it may create uncertainty for purchasing, production, import planning, customer delivery, and market access.

Step-by-Step TSCA SNUR Applicability Review

A practical SNUR review should answer five core questions.

Practical Compliance Checklist

Companies should build a repeatable TSCA SNUR compliance process instead of relying on one-time manual checks.

What Documentation Should Companies Keep?

A defensible TSCA SNUR compliance file should include:

• Substance identity and CAS information where available
• Supplier identity and supplier declarations
• Product, material, mixture, or component mapping
• Applicable 40 CFR Part 721 references
• SNUR screening results
• Intended use and actual use description
• Manufacturing, importing, processing, distribution, disposal, and release information
• Workplace protection and hazard communication information
• Import applicability review
• Export notification review where relevant
• SNUN decision record
• Internal compliance approval before activity begins
• Supplier, formulation, and customer-use change history
• Supporting communications and technical evidence

The purpose of this documentation is to show that the company made a controlled, evidence-based decision before manufacturing, importing, or processing.

Common TSCA SNUR Compliance Mistakes

1. Treating SNURs as a simple chemical list check

SNUR compliance is not only about whether a substance appears on a list. The real question is whether the company’s activity is a designated significant new use.

2. Assuming “TSCA compliant” supplier statements are enough

A general supplier statement may not confirm substance identity, exact use conditions, exposure controls, release pathways, or whether a SNUN is required.

3. Forgetting that import counts as manufacture

Importers are directly affected because TSCA defines manufacture to include import. This makes SNUR screening important before shipment, customs certification, and U.S. market entry.

4. Missing supplier or formulation changes

A supplier change, alternative material, replacement additive, or new formulation can change the substance profile and trigger a new review.

5. Not connecting procurement, R&D, and compliance teams

SNUR risk can appear during product development, supplier onboarding, sourcing changes, or customer-specific applications. If teams work separately, the compliance risk may be identified too late.

6. Relying on spreadsheets and emails

Manual tracking makes it harder to prove what was checked, when it was checked, who approved it, and whether supplier information was complete.

FAQ: TSCA SNUR Compliance

What is a SNUR?

A Significant New Use Rule is an EPA rule that identifies a specific use of a chemical substance as a significant new use under TSCA Section 5(a)(2). Before starting that activity, companies may need to submit a SNUN to EPA.

What is a SNUN?

A Significant New Use Notice is the notification submitted to EPA before manufacturing, importing, or processing a chemical substance for a designated significant new use. EPA states that the SNUN must be submitted at least 90 days before the activity begins.

Does a SNUR ban a chemical substance?

Not necessarily. A SNUR usually creates a pre-manufacture, pre-import, or pre-processing notification requirement for a specific significant new use. EPA then reviews the intended activity before it begins.

Are importers affected?

Yes. TSCA defines manufacture to include import, and EPA confirms that the SNUN requirement applies to imports involving new uses of chemicals.

Where are SNUR requirements found?

SNUR requirements are primarily found in 40 CFR Part 721, which covers Significant New Uses of Chemical Substances.

When should a company review SNUR applicability?

Companies should review SNUR applicability before manufacturing, importing, processing, reformulating, changing suppliers, changing customer applications, or starting a new use of a chemical substance.

How ComplyMarket Product Compliance Software Can Help

TSCA SNUR compliance becomes difficult when substance information, supplier declarations, product data, and regulatory decisions are scattered across emails, spreadsheets, PDFs, and disconnected systems.

ComplyMarket helps companies create a more structured and traceable product compliance process. ComplyMarket’s material compliance software is designed to collect compliance and sustainability information from suppliers, manage chemicals and risk, and support product and material compliance across the supply chain.

For TSCA SNUR compliance, ComplyMarket can help companies:

• Centralize supplier, material, product, component, and substance data
• Collect supplier declarations through structured compliance workflows
• Map substances to products, components, materials, and suppliers
• Identify which products or materials may require TSCA screening
• Support regulatory change monitoring and compliance evidence tracking
• Maintain documentation for internal reviews, customer requests, and audits
• Improve traceability when suppliers, formulations, or product uses change
• Reduce reliance on manual spreadsheets and scattered email follow-ups
• Support risk-based decisions before importing, manufacturing, or processing begins

ComplyMarket also describes material compliance management as controlling composition data across materials, parts, assemblies, finished goods, and packaging so companies can meet market-access rules, supplier communication duties, technical documentation requirements, and customer declaration requests.

For a company managing TSCA SNUR obligations, this means ComplyMarket can help answer critical business questions faster:

• Which suppliers provide substances or materials that need TSCA review?
• Which products may contain substances subject to a SNUR?
• Do we have enough supplier data to assess use conditions?
• Can we prove why a SNUN was or was not required?
• Are supplier, formulation, or application changes being reviewed before they create compliance risk?
• Is our compliance evidence organized, traceable, and ready for review?