U.S. EPA Proposes Significant New Use Rules for 27 Chemical Substances

On July 24, 2026, the U.S. Environmental Protection Agency (EPA) published a proposed rule in the Federal Register to seek public comments on Significant New Use Rules (SNURs) for 27 chemical substances under the framework of the Toxic Substances Control Act (TSCA). The comment deadline is August 24, 2026.

Chemical Substances Involved

The 27 chemical substances subject to control span multiple sectors including electronics, coatings, detergents, plastic additives, and photolithography materials:

Generic Name	Principal Use	Significant New Use
Polysaccharide ether chloride	Additive in consumer/commercial products	• Manufacturing with amine nitrogen substitution degree exceeding the confidential percentage listed in the order; • Release to surface water resulting in concentrations exceeding 193 ppb (exempting processors/users receiving formulation concentrations <5.5%); • Failure to establish a hazard communication program.
Heteroatom-substituted dihaloester	Electrolyte additive	• Manufacture or processing without personal protective equipment (PPE) when dermal exposure is possible; • Use in consumer products; • Manufacture/processing/use not in a closed process; • Waste disposal not via incineration; • Failure to establish a hazard communication program.
Rhamnolipids (various salts)	Detergents, cleaners	• Any manufacturing or processing method resulting in inhalation exposure; • Concentration exceeding 3% by weight in final formulation (including consumer products); • Failure to wear a NIOSH-certified respirator (APF ≥ 50) when inhalation exposure is possible; • Failure to use PPE when dermal exposure is possible.
Carbon monocyclic alkyl amide (potential PBT chemical)	Plastic additive	• Use in consumer products; • Manufacture/processing/use in non-liquid solution form; • Any method resulting in inhalation exposure; • Release to water; • Failure to establish a hazard communication program.
Bisphenol-epichlorohydrin type polymers (12 substances)	Coatings for metal parts	• Cationic amine nitrogen content exceeding 2% by weight; • Any method resulting in inhalation exposure; • Failure to capture and destroy all vapors/aerosols/dusts/mists containing the substance through engineering controls (e.g., thermal oxidation) with destruction efficiency below 98%; • Use in consumer products; • Release to surface water resulting in total concentration of the 12 substances exceeding 11 ppb (9 ppb for P-24-121 alone); • Failure to establish a hazard communication program.
Polyoxyethylene acrylate CASRN: 478549-43-8	Paints, coatings, inks	• Failure to use PPE when dermal exposure is possible; • Failure to wear a NIOSH-certified respirator (APF ≥ 50) when inhalation exposure is possible; • Use in consumer products; • Spray application using non-automated spray booths; • Release to water; • Failure to establish a hazard communication program.
Polyfluorinated sulfonium salts (potential PBT chemicals)	Photolithography	• Manufacture beyond the time limit specified in the order (9 months for P-25-98/99; 18 months for others) without submitting the required Tier I and Tier II testing; • Failure to use PPE when dermal exposure is possible; • Failure to establish a hazard communication program; • Generation of vapors/dusts/mists/aerosols in non-enclosed processes; • Use for purposes other than the confidential uses listed in the order; • Domestic manufacture (importation only); • Failure to dispose of waste via incineration in compliance with RCRA Subtitle C; • Importation in non-solution form (unless in sealed containers ≤5 kg); • Import volume exceeding the confidential annual quantity listed in the order.
Aromatic sulfonium salts/iodonium salts (5 substances) (potential PBT chemicals)	Photolithography/electronics industry	• Domestic manufacture (importation only); • Importation in non-solution form unless in sealed containers with single-unit weight ≤5 kg; • Import volume exceeding the confidential annual quantity listed in the order; • Manufacture beyond the time limit specified in the order (9 months for P-25-98/99; 18 months for others) without submitting the required Tier I and Tier II testing; • Use for any purpose other than the confidential uses listed in the TSCA order; • Generation of vapors/dusts/mists/aerosols in non-enclosed processes; • Failure to use PPE when dermal exposure is possible; • Failure to implement engineering or administrative controls (e.g., enclosure, ventilation) to prevent worker exposure; • Failure to dispose of waste via incineration in compliance with RCRA Subtitle C.

Note: Most substances do not have publicly available CASRNs, as their chemical identities have been claimed as Confidential Business Information (CBI).

CIRS Insights

If this proposed rule is finalized, any enterprise that manufactures, imports, or processes any of these 27 chemical substances for a "significant new use" must submit a Significant New Use Notice (SNUN) to the EPA at least 90 days in advance. The affected enterprise may commence the relevant activity only after the EPA has completed its risk assessment and issued a determination. The primarily affected industries include chemical manufacturing (NAICS 325), petroleum refining (NAICS 324110), and related import trade. Since the specific identities of most chemical substances have been claimed as CBI, enterprises uncertain whether their products are subject to control may submit a "bona fide intent" application to the EPA to confirm the substance identity.

CIRS Services

TSCA Inventory and confidential inventory searches
Compliance strategies for existing substances listed on the TSCA Inventory
Pre-Manufacture Notice (PMN) exemptions (substances under other regulatory jurisdictions, substances for R&D, low-volume substances, polymers, etc.)
Pre-Manufacture Notices (PMNs)
Significant New Use Notices (SNUNs)

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

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