Frequent Questions

Where EPA has recognized a particular use of a SNUR chemical in a product as ongoing, and therefore has not made the use subject to the SNUR, is a reformulation of that product for the same general use considered a new use of the SNUR chemical?

If a significant new use contains a maximum content threshold (e.g., use at greater than a given level in a mixture), any reformulations that would cause that subject chemical substance to be greater than the specified level would be subject to the SNUR.

 

A specific example is the SNUR for dipropylene glycol dimethyl ether at 40 § CFR 721.3550 that states that “Formulations or mixtures containing the PMN substance in concentrations at or below 10 percent by weight or volume are exempt from the provisions of this rule.” Reformulations that meet the definition of the significant new use and increase the concentration above ten percent by weight or volume would require a SNUN. Reformulations that do not increase the concentration above ten percent by weight or volume would not require a SNUN.

If 1) the significant new use identified in the SNUR is not concentration limited, 2) the reformulation is not associated with a different use, and 3) the use is an ongoing use, then the reformulation in itself would not be subject to the SNUR because it would not be considered a significant new use.

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