On October 15, 2026, EPA published a final rule in the Federal Register (91 FR 65461, FRN 2026-21051) issuing significant new use rules under the Toxic Substances Control Act for 19 chemical substances. The rule is effective December 14, 2026. EPA finalized it as proposed on June 10, 2026.
This post covers what a SNUR does, what these 19 substances have in common, what the conditions look like, how importers are affected, and what to do now.
What a SNUR requires
A SNUR designates certain activities as a significant new use. Anyone who intends to manufacture or process the substance for that use must submit a significant new use notice (SNUN) to EPA at least 90 days before starting. By statute, manufacture includes import. The activity cannot begin until EPA has reviewed the notice, made a determination, and taken any action that determination requires.
It is not a ban on the chemicals. It is a gate on uses outside the conditions EPA has already set.
What these 19 have in common
Each substance was the subject of a premanufacture notice and is covered by an EPA order under TSCA section 5(e)(1)(A). Those orders require protective measures to limit exposure or reduce potential unreasonable risk, and they bind only the company that holds the order. The SNURs extend the same limits to everyone by designating any manufacturing, processing, use, distribution, or disposal that does not conform to the order’s restrictions as a significant new use.
What the conditions look like
They vary by substance. Common ones are hazard communication, worker protection with specified respirator levels, bans on uses that cause inhalation exposure, and limits on release to water. Some are narrow use restrictions. One substance may be used only in the polyol side of a spray polyurethane foam formulation. Another may be processed or used only as a catalyst in two-part spray foam insulation, at no more than 3 percent by weight in a formulation. One benzoic acid ester may not be used above 5 percent by weight in a formulation. A polymer may only be brought in as a liquid solution, with no domestic manufacture, and used only as a construction adhesive sealant foam. Two substances tied to semiconductor photolithography may not be imported other than in solution unless in sealed containers weighing 5 kilograms or less. Several limits, including production volumes and concentrations, refer to confidential figures in the underlying orders.
Several of the SNURs exclude the substance once it is in an article, or once it has been completely reacted or cured.
How importers are affected
The notice says the rule may reach importers through existing TSCA requirements. Chemical importers are subject to TSCA section 13, 19 CFR 12.118 through 12.127, and 40 CFR part 707 subpart B. Importers of chemical substances in bulk form, as part of a mixture, or as part of an article if required by rule must certify that the shipment complies with all applicable TSCA rules and orders. Commentary on an earlier SNUR batch treated certification as attaching once the rule is final and effective, so confirm with your broker how it will apply to these 19 from December 14. Exporters are subject to the section 12(b) notification rules, which require a one-time notice for the first export to a given country, at an estimated cost of about $106.
Anyone who began a use that the final rule designates as significant after the June 10 proposal, and before December 14, would have to stop on the effective date and file a SNUN to resume.
The identification problem
14 of the 19 are listed under generic names because the actual identity is claimed as confidential business information. A product label or a tariff description will not tell you whether you are importing one. The answer has to come from the supplier.
Cost and timing
EPA estimates a SNUN costs about $45,000 for a large business and $14,500 for a small one, including a user fee of $37,000 or $6,480. It estimates 30 to 170 hours of work per submission. A 90-day wait comes on top of that, and EPA’s review can extend it. EPA also notes that submitting without test data may increase the chance it takes further action.
What to do now
Ask your suppliers whether any chemical or mixture you import contains one of the substances. Ask for the TSCA status and any order conditions that apply, since the generic names will not let you check on your own. Compare your intended use, form, concentration, and packaging with the conditions in the rule. And agree with your broker how TSCA certification will be handled on entries from December 14.
We are helping clients check their chemical imports against the 19 substances. If you want a review, reach out to your ShipTech account manager.