During the recent 2023 CAD RETEC conference in Columbus, OH, CPMA Executive Director Dave Wawer participated in a regulatory panel and discussed key components of the Toxic Substances Control Act (TSCA) that plastics masterbatch companies should take into consideration for future business planning. EPA has revised existing regulations or eliminated long-standing policies with respect to the TSCA Inventory, new chemicals applications (PMNs), chemicals data reporting, chemicals risk evaluation, and chemicals risk management. For example, manufacturers, importers and distributors are now subject to $5.6 million fees for chemicals risk evaluations, proportional to US volume.
C.I. Pigment Violet 29 (PV29), a perylene pigment, is at the beginning stage of EPA’s risk management rule process. Although PV29 is recognized as a high performance, low-volume substance, EPA’s final regulatory considerations could include bans, restrictions, labeling notifications or other regulatory requirements for plastics processors and converters. More importantly, this first risk management rule establishes the regulatory floor for every commercial pigment used for plastics masterbatch applications, including TiO2 and Carbon Black.
Companies in the batch specialty chemical manufacturing sector, particularly processors and converters, are becoming aware of the extent to which the 2016 Lautenberg Chemical Safety Act (TSCA Reform) affects their companies, their customers, and their suppliers. Imagine being informed by a supplier that a raw material traditionally used for plastics masterbatch operations has been banned for use by EPA, or that its use is limited to specific downstream customers, or that its use requires additional labeling, potentially in conflict with OSHA Hazard Communications regulations. EPA has already promulgated chemicals risk management rules for several solvent substances, resulting in bans for specific types of uses or industrial applications.
Plastics masterbatch companies have traditionally focused on downstream customer and consumer brands needs and requirements in the process of developing new products. What we are seeing in the regulatory environment in the US today is a paradigm shift that will affect uses of chemical substances throughout the supply chain.
To learn about CPMA programs offering regulatory support for the color pigments industry, contact David Wawer at davidwawer@cpma.com.
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