Frequent Questions

Where the significant new use for a SNUR chemical is use in a consumer product, and a consumer product containing the SNUR chemical is manufactured in multiple steps by different producers, at what point in the supply chain does the product become subject

The fact that the chemical substance is in a consumer product does not limit the downstream notification at 40 CFR 721.5. The SNUN submission requirement applies at the earliest point where a person intends to manufacture (including import), or process for commercial purposes the chemical substances for a significant new use (e.g., use in a consumer product). In addition, a person who intends to manufacture(including import) or process the chemical substance for commercial purposes and intends to distribute the substance in commerce must submit a SNUN unless they follow one of the alternatives described at 40 CFR 721.5(a)(2) (e.g., downstream notifications).

 

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