[Home](/)/[Resources](/resources)/EPA TSCA Chemical Reporting USChemicals # US EPA TSCA: Chemical Data Reporting and New Chemical Notifications for Electronics TSCA is the foundational US chemical regulation — and for electronics companies, the article exemption only goes so far. With PFAS reporting now extending to imported articles and Section 6 risk evaluations accelerating, understanding where TSCA obligations start and stop is essential for any hardware company with US operations or sales. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fus-epa-tsca-chemical-reporting) At a glance Law TSCA (15 USC §2601) Administrator US Environmental Protection Agency (EPA) CDR Every 4 years for 25,000 lb+ manufacturers/importers PMN Required for new chemical substances not on TSCA Inventory ## TSCA obligations that affect electronics companies ### TSCA Inventory and the CDR The TSCA Chemical Substance Inventory lists all chemicals in US commerce. Manufacturers and importers of chemicals on the Inventory at 25,000 lbs/year or more must submit Chemical Data Reports (CDR) to EPA every four years. The CDR collects production volume, exposure, and use data that EPA uses to prioritise risk evaluations under TSCA Section 6. ### Pre-Manufacture Notice (PMN) for new chemicals Any chemical not already on the TSCA Inventory that will be manufactured in or imported into the US must have a PMN submitted to EPA at least 90 days before manufacture begins. EPA reviews the PMN and may impose consent orders, significant new use rules (SNURs), or restrictions. If EPA takes no action within 90 days, the company may proceed — but any restriction imposed during review remains binding. ### Article exemption for finished electronics Generally, chemicals that are part of a finished article — a completed electronic product — are exempt from TSCA chemical reporting obligations. However, this exemption does not extend to chemicals released from the article during normal use, nor to chemicals used in US manufacturing processes (such as etching agents, fluxes, and cleaning solvents). Electronics companies with US manufacturing operations face more extensive TSCA obligations than pure importers of finished goods. ### TSCA Section 6 restrictions EPA uses TSCA Section 6 to restrict or ban specific chemicals presenting unreasonable risk. Restrictions directly relevant to electronics include PCB prohibitions, asbestos restrictions, and the PFAS reporting rule under TSCA Section 8(a)(7) — which requires reporting on all PFAS manufactured or imported since 2011, including those in articles. The PFAS rule is one of the broadest TSCA obligations to affect electronics importers in recent years. ## Mapping your TSCA obligations step by step 01 Determine whether your company manufactures or imports chemical substances into the US. Finished electronic goods assembled outside the US and imported as articles are generally TSCA-exempt; chemical components manufactured or imported in bulk form — including chemicals used in US production processes — are not exempt and may trigger CDR or PMN obligations. 02 Check the TSCA Chemical Substance Inventory (searchable via EPA's Chemical Dashboard at comptox.epa.gov) for any substances you manufacture or import. If a substance is not listed on the active Inventory, a Pre-Manufacture Notice must be submitted to EPA before US manufacture begins. 03 For CDR-obligated companies manufacturing or importing 25,000 lbs or more of a listed substance in a principal reporting year: prepare and submit the CDR to EPA through the CDX reporting portal during the applicable reporting window. The CDR collects data on production volume, industrial processing, and consumer use. 04 Monitor EPA's TSCA Section 6 rulemaking docket for emerging restrictions affecting electronics materials. PFAS (perfluoroalkyl and polyfluoroalkyl substances), persistent organic pollutants, and certain brominated flame retardants are active areas of TSCA regulatory activity — restrictions in these areas can affect component sourcing with relatively short lead times. 05 If your US manufacturing operations use process chemicals — etching agents, cleaning solvents, fluxes — review your obligations under TSCA Section 8(e). Information indicating that a chemical presents a substantial risk of injury to human health or the environment must be reported to EPA immediately, typically within 30 days of obtaining such information. ## Frequently asked questions ### Are imported finished electronics exempt from TSCA? Finished electronic products imported as articles are generally exempt from TSCA chemical reporting because chemicals bound within the article are not considered to be 'manufactured for commercial purposes' in the traditional sense. However, this exemption has important limits: the TSCA PFAS Section 8(a)(7) reporting rule specifically requires reporting on PFAS in imported articles, covering PFAS manufactured or processed since 2011. Electronics importers should treat PFAS as a live TSCA obligation regardless of article status. ### What chemicals in electronics are subject to TSCA Section 6 restrictions? Key electronics-relevant TSCA Section 6 restrictions include: PCBs (polychlorinated biphenyls) — prohibited in most applications; asbestos — EPA issued a final rule in 2024 banning most remaining uses; and ongoing risk evaluations for certain PFAS and persistent bioaccumulative toxicants (PBTs). EPA's TSCA prioritisation list is the best source for emerging restrictions. Companies should review the list against their materials, particularly for cleaning solvents, dielectric fluids, and conformal coatings. ### What is the difference between CDR and PMN under TSCA? The CDR (Chemical Data Report) is a periodic reporting obligation for existing chemicals already on the TSCA Inventory, triggered by production/import volume above 25,000 lbs/year. It reports data on chemical use but does not require prior EPA approval. The PMN (Pre-Manufacture Notice) is a pre-market notification for new chemicals not on the TSCA Inventory — it must be submitted 90 days before US manufacture begins, and EPA may impose restrictions during the review period. PMN is a one-time gating step; CDR is a recurring reporting obligation. ### How does TSCA PFAS reporting affect electronics companies? EPA's PFAS reporting rule under TSCA Section 8(a)(7) requires any company that manufactured or imported PFAS — including in articles — since January 1, 2011 to submit a one-time report to EPA. Electronics companies are significantly affected because PFAS are widely used in printed circuit boards (PTFE substrates), cable insulation, semiconductors, and water-resistant coatings. The reporting obligation covers a wide range of PFAS structures, including precursors. Companies that imported PFAS-containing electronics must evaluate whether they meet the rule's reporting threshold. **Disclaimer:** Educational resource only. Regulatory requirements change and vary by product category. Consult an accredited test laboratory or qualified compliance engineer before making certification decisions. 🇺🇸 US roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇺🇸 US compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/55-us-hazardous-nonhazardous-chemicals-compliance)[Prefer to read? 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