EPA TSCA Compliance Checklist for US Importers

Use this checklist before any shipment containing chemicals, chemical mixtures, or articles with chemical substances enters the United States.

1. **Confirm whether your chemical is new or existing.** Check the TSCA Inventory listing to see if your substance is already recognized; if not, it counts as new.

2. **File a TSCA Section 5 PMN if the chemical is new.** A Premanufacture Notice is required before a new chemical substance can be manufactured or imported.

3. **Check PCB levels against the 50 ppm limit.** Any polychlorinated biphenyls above this threshold are restricted under EPA TSCA.

4. **Verify asbestos is not present in new uses.** Asbestos in new uses is banned outright, with no allowable limit.

5. **Get SVOC/PCB test results from your supplier.** Lab results documenting semi-volatile organic compound and PCB levels should accompany the shipment.

6. **Complete a TSCA Section 13 Import Certification.** This certifies that the shipment either complies with TSCA or is excluded from it, and it travels with your customs paperwork.

7. **Match documents to the specific shipment.** Test results and certifications should correspond to the actual batch or lot being imported, not a general product line.

8. **Keep records on file, not just on hand at the port.** Having documents ready for customs is one step; being able to produce them later if asked is another.

9. **Ask suppliers directly whether they track EPA TSCA requirements.** Many manufacturers outside the US are unfamiliar with TSCA Inventory status or Section 13 certification, so confirm rather than assume.

This list covers the documents and checks most small importers encounter, but TSCA requirements vary by chemical type and end use, so treat this as a starting point rather than a full compliance determination.

For background on how EPA TSCA fits into US import rules, see [EPA TSCA](/regulations/epa-tsca). If you're trying to get this information from suppliers who may not use these terms themselves, our [supplier compliance](/supplier-compliance) tools can help structure those requests.

If you want help turning this checklist into something you can track shipment by shipment, Complyra is worth a look.