Requirements for Submitting Electronic Pre-manufacture Notices (PMNs)
Speak to a Specialist
The CDX Hotline (firstname.lastname@example.org) can answer technical questions about the ePMN and CDX at:
970-494-5500 (international callers)
Complete PMN Forms Using e-PMN Software and Submit through Central Data Exchange (CDX)
On January 6, 2010, EPA issued a final rule requiring:
- Use of e-PMN software to fill out TSCA section 5 Premanufacture Notice (PMN) forms beginning April 6, 2010;
- Phase-in over a two-year period the mandatory use of EPA's Central Data Exchange (CDX) to electronically submit PMNs and other documents under TSCA section 5.
Note: All new TSCA section 5 PMNs must be submitted electronically through CDX and must use e-PMN software. On December 4, 2013, EPA issued a final rule requiring:
- Use of e-PMN software and CDX to submit all Notices of Commencement (NOCs) beginning (March 4, 2014); and
- Use of e-PMN software and CDX to submit support documents for TSCA section 5 notices originally submitted prior to April 6, 2010.
EPA is providing two different variations of the e-PMN software, one with encryption and one without encryption. The links to the e-PMN software without encryption, Helpful Hints for the e-PMN software, and webinars for CDX registration and e-PMN software can be found below. The download link to the e-PMN software with encryption can be found on EPA's CDX registration website once submitters have registered with CDX and EPA has approved their registration.
Read more about the rule (PDF) (65 pp, 1.2MB).
On this page you will find:
- Central Data Exchange
- Central Data Exchange eTSCA/e-PMN Registration User's Guide
- Helpful Hints for CDX Registration and Submission of the e-PMN
- CDX Registration
- e-PMN software (without encryption software)
- Electronic Toxic Substances Control Act (eTSCA)/e-PMN Reporting Tool (e-PMN User's Guide)
- Helpful Hints for Use of the eTSCA/e-PMN Submission Software
- e-PMN Software Download
- Registration and software definitions
- e-PMN webinars
The e-PMN software enables manufacturers (including importers) of TSCA chemical substances to use the Internet, through EPA's CDX, to submit TSCA section 5 notices to the Agency. These notices include:
- PMNs, Significant New Use Notices (SNUNs)
- Test Market Exemption (TME) applications
- Low Volume Exemption (LVE) notices
- Low Exposure/Low Release (LoREX) exemption notices
- Biotechnology Notices for genetically modified microorganisms
- Notices of Commencement of Manufacture (including Import) (NOCs)
- Support documents for section 5 notices (e.g., correspondence, requests for suspensions of the notice review period, amendments, letters of withdrawal, and test data).
In order to submit documents electronically to EPA, you must pre-register with CDX and be approved by EPA. Two types of submitters may register with CDX: Authorized Officials and Support Registrants. Refer to Helpful Hints for CDX (PDF) (10 pp, 43K) for more information on the registration process and who may submit.
If you have technical issues or problems regarding the e-PMN software or CDX registration, please contact the CDX Help Desk at email@example.com or 888-890-1995. International callers who wish to contact the Help Desk should call 970-494-5500. If you have programmatic questions, please contact Kathryn Schechter at 202-564-8589 or e-mail Schechter.Kathryn@epa.gov, Anna Coutlakis at 202-564-9207 or e-mail Coutlakis.Anna@epa.gov, or Loraine Passe at 202-564-9064 or e-mail Passe.Loraine@epa.gov.
Central Data Exchange (CDX)
Central Data Exchange eTSCA/e-PMN Registration User's Guide (PDF) (44 pp, 8.6MB) (CDX User's Guide - This guide describes how to use CDX to submit TSCA section 5 documents to EPA via the Internet.)
e-PMN Software Download (version WITHOUT encryption software)
Electronic Toxic Substances Control Act (eTSCA)/e-PMN Reporting Tool (PDF) (68 pp, 4.6MB) (e-PMN User's Guide - This guide describes how to use the e-PMN tool to create various TSCA section 5 reporting forms.)
PLEASE UNINSTALL ANY PRE-EXISTING eTSCA/e-PMN SOFTWARE BEFORE DOWNLOADING THE SOFTWARE VERSION BELOW.
NOTE: This software cannot be used to submit electronically via CDX; submit via an optical CD.
eTSCA/e-PMN Client Download for software without encryption.
Registration and Software Definitions
Who is an Authorized Official and what can an Authorized Official submit?
An Authorized Official is a person in a company legally responsible for the data in the notice submission. Generally this would be the person who signs the certification page on the paper version of the PMN form. Under CROMERR, the person who submits a document via CDX is equivalent to this wet-ink signature.
An Authorized Official may submit any section 5 document via CDX to EPA. This includes section 5 Notices (PMN, SNUN, LVE, TMEA, LoREX, Modifications to LVE and LoREX, Biotechnology, NOC and Letters of Support) and support documents to the section 5 Notices (amendments, test data, and correspondence). Note: Only Authorized Officials may submit section 5 Notices.
Who is a Support Registrant and what can a Support Registrant submit?
A Support Registrant is a person designated by an Authorized Official to submit supporting documents on behalf of an Authorized Official. The Support Registrant can be another person from the Authorized Official's company or can be an agent or consultant from outside the company.
A Support Registrant may submit only support documents to section 5 Notices (amendments, test data, and correspondence). Note: Only Authorized Officials may submit section 5 Notices.
Why are there two versions of the e-PMN software?
EPA needed to limit accessibility of e-PMN software that contained the encryption software (FIPS-validated RSA BSAFE Crypto-J) because of Export Administration regulations. Therefore, the Agency made a more easily accessible version of the e-PMN software available that does not contain the encryption portion of the software.
- CDX Registration Webinar and questions and answers from January 21, 2010, webinar
- e-PMN Software Webinar from March 16, 2010
- e-PMN version 2.0 software webinar from February 16, 2012
- e-PMN version 2.0 software webinar from August 1, 2012, slides and audio
- Bona Fide Notices and Alternative Control Measures in e-PMN version 2.0 software webinar from December 4, 2013, slides and audio
- PMNs, joint submissions, and letters of support in e-PMN version 2.0 software webinar from December 5, 2013, slides and audio
- CDX registration webinar from December 17, 2013, slides and audio