Next Five Substances for Prioritization Under TSCA: Potential Regulatory Challenges for Organic Pigments Manufacturers, Importers, and Distributors

In December 2023, USEPA announced that it intends to prioritize five chemical substances for Risk Evaluation under the Toxic Substances Control Act (TSCA) in 2024. If these chemicals are designated as high priority substances at the end of the 9–12-month prioritization process, they will undergo Risk Evaluation.

One of the five substances for prioritization is Benzenamine, a critical raw material used to manufacture specific organic pigments. The substance is also an important raw material in the manufacture of organic dyes. Based upon CPMA’s experience with the Risk Evaluation of CI Pigment Violet 29, EPA will most likely incorporate all known downstream uses, as well as hypothetical future uses as part of the Risk Evaluation process for Benzenamine.

In addition, based upon Risk Management Rules promulgated for the first ten priority chemicals Risk Evaluations, EPA will likely adopt a similar regulatory approach - ban or severely restrict the manufacture of Benzenamine, as well as downstream uses of Benzenamine in pigments and dyes. This approach puts at risk current global supply chains for organic pigments, along with downstream colors applications used by global companies in commercial and consumer products.

CPMA’s advocacy and technical committees are gearing up in 2024 to provide strategic analytical support for organic pigments manufacturers, importers, and distributors to assist in navigating through the regulatory process and potential impacts for the industry.

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