BRAG Requests that EPA Adopt TSCA Inventory Representation and Equivalency For Renewable and Sustainable Biobased Chemicals
Washington D.C.: Representatives of the Biobased and Renewable Products Advocacy Group (BRAG®) and representatives of the Biotechnology Innovation Organization (BIO) met with U.S. Environmental Protection Agency (EPA) staff to discuss the two groups’ recently-issued white paper, “Proposal for a Toxic Substances Control Act (TSCA) Inventory Representation and Equivalency Determinations for Renewable and Sustainable Bio-based Chemicals.” BRAG and BIO members provided a presentation for EPA staff that outlined the regulatory challenges and market impedance facing the biobased industry related to current naming conventions.
TSCA, the U.S. law that regulates both existing and new industrial chemicals introduced for commercial purposes, is interpreted and applied by the U.S. Environmental Protection Agency (EPA) in ways that often make it difficult for new biobased chemicals and, more importantly, their derivatives to enter the market easily if at all. The premarket review process often results in many biobased chemicals being subjected to restrictions beyond those that are applied to chemically identical substances with a petroleum source or those derived from traditional seed and vegetable oils that are already on the market. The source- and process-based TSCA naming system for certain chemicals acts as a significant barrier to the adoption of novel bio-based chemicals, hampering commercialization and inviting considerable delays to market entry while taking up more of EPA’s already limited resources.
BRAG and BIO have requested that EPA develop naming guidance for bio-based substances and production sources because current resources are scant, scattered, and dated. Creating comprehensive source- and process-agnostic naming guidance for these chemicals and adopting a constituent-based naming system would level the playing field for biobased chemicals and allow customers more freedom in selecting a greener chemical that is derived from a variety of renewable sources. Any company or organization intending to market biobased products — whether they come from plants, algae, or restaurant waste — should read this white paper and join BRAG in the effort to create a more sensible regulatory approach.
For more information, please contact Kathleen Roberts, Executive Director of BRAG, at kroberts@bc-cm.com or (202) 833-6581.