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How to File a Notice of Commencement (NOC)

A new chemical is added to the TSCA Inventory after the PMN review period has completed/expired and the PMN submitter has commenced nonexempt commercial manufacture. The submitter of the PMN must provide a Notice of Commencement (NOC) of Manufacture or Import Form to EPA within 30 calendar days of the date the substance is first manufactured (which includes import) for nonexempt commercial purposes. The chemical substance is considered to be on the TSCA Inventory and an existing chemical as soon as a complete NOC is received by EPA. Actual EPA processing of the NOC to complete the transaction takes about four weeks.

As of April 6, 2012, all NOCs for PMNs submitted on or after April 6, 2010 (i.e., the effective date of the electronic-PMN ("e-PMN") final rule (75 FR 773) (PDF) (18 pp, 110K, about PDF)), must be submitted electronically to EPA using the e-PMN software via Central Data Exchange (CDX). As of March 4, 2014, (i.e., the effective date of the e-TSCA rule), NOCs for PMNs submitted prior to April 6, 2010, must also be submitted electronically to EPA using the e-PMN software via CDX. Refer to www.epa.gov/cdx, the CDX Registration Guide (PDF) (44 pp, 8.6MB, about PDF), or the CDX Helpful Hints (PDF) (10 pp, 41K, about PDF) for directions on how to register and submit notices via CDX.

Excess R&D substance may be used or sold after expiration of the PMN review period and does not require submission of a NOC. The substance will not be placed on the Inventory until an NOC is received; however, a NOC may not be submitted for the substance before commercial manufacture (non-R&D) begins.

Use of EPA Form 7710-56 became compulsory for NOCs filed after the effective date of the amended regulations published March 29, 1995. (60 FR 16336-16351).


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