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August 1, 2013

Lynn L. Bergeson, Charles M. Auer, and R. David Peveler, “TSCA and the Regulation of Renewable Chemicals,” American Oil Chemists, July/August, 2013.

Bergeson & Campbell, P.C.

While regulators are generally supportive of new chemistries that can replace older, petroleum-based ones, biobased chemicals are subject to the same Toxic Substances Control Act (TSCA) that governs every other chemical substance in the United States. Surprisingly, biobased chemicals that are considered to be “new chemicals” may actually receive more scrutiny under this law than established chemicals do. The following article provides practical information about the TSCA provisions that are most relevant to biobased chemicals, regulatory outcomes of Premanufacture Notification (PMN) review, and strategies stakeholders can use to assure compliance and successful commercialization of biobased chemicals.