The EPA TSCA SNUR proposed in July 2026 introduces significant new use rules for 14 chemical substances, and one obligation is already live even though the rule is not final. Published on July 30, 2026 as FR Doc 2026-15352 (91 FR 48044), the proposed rule extends the protective measures of existing TSCA Orders to every manufacturer, importer, and processor of these substances. For compliance teams at global manufacturers, the immediate task is not to wait for finalization. It is to screen bills of materials against the covered substances now and to check export exposure before the comment period closes on August 31, 2026.

This guide explains what the proposed SNUR covers, which obligations attach today versus at finalization, the industries most exposed, and the practical steps to prepare. If you need a fast read on your own exposure, you can request a compliance review to map these substances across your product portfolio and supplier base.

Key Takeaways

📌 The proposed EPA TSCA SNUR (26-4), published at 91 FR 48044, covers 14 premanufacture notice (PMN) substances under TSCA Section 5(a)(2). Comments close August 31, 2026.

⏳ One obligation is already live. TSCA Section 12(b) export notification applies to exports of any covered substance on or after August 31, 2026, even though the rule is still a proposal.

⚠️ TSCA Section 13 import certification and the 90-day significant new use notice (SNUN) obligation attach only when the SNUR is finalized. Applying Section 13 duties now is the most common error at proposal stage.

🏭 Semiconductor and electronics manufacturers carry the highest exposure, including tertiarybutylarsine (P-25-77) and two import-only photoresist salts flagged as potential PBT substances.

📊 A SNUN submission is estimated at $45,496 for a large business or $14,976 for a small business, including a $37,000 or $6,480 user fee. Each export notice runs about $106.

🔗 The designated significant new use is identical for all 14 substances: any activity that departs from the protective measures in the underlying TSCA Order.

🤖 BOM-level substance screening and continuous regulatory intelligence let teams identify exposure across products and suppliers before the rule is final.

What Is the EPA TSCA SNUR 2026 (26-4)?

A significant new use rule (SNUR) is issued under TSCA Section 5(a)(2), which lets EPA designate a use of a chemical substance as a "significant new use." Once that designation is final, anyone intending to manufacture, import, or process the substance for that use must notify EPA at least 90 days in advance through a SNUN.

This particular batch, identified as 26-4, is built on existing TSCA Section 5(e) Orders. Each Order was negotiated with the original PMN submitter and requires protective measures such as personal protective equipment, enclosed processing, and release limits. The proposed SNUR extends those same restrictions to all persons, consistent with TSCA Section 5(f)(4). You can review the full framework on Certivo's TSCA compliance page and confirm the primary text through the Federal Register notice.

The legal basis is the standard insufficient-information pathway under TSCA Sections 5(a)(3)(B)(ii)(I) and 5(e)(1)(A)(ii)(I). This is a finding that, absent enough data for a reasoned evaluation, the substance may present an unreasonable risk. It is not a finding of demonstrated harm.

The 14 Chemical Substances Covered

The proposed rule lists 14 substances by PMN number. Screening your BOM-level material data against this list is the single most useful action a compliance team can take today.

Order effective dates across the batch range from June 26, 2025 to April 14, 2026. P-21-36 reflects a modified Order rather than a new one, effective April 14, 2026.

What Obligations Attach Now Versus at Finalization

This is the point most easily mishandled with a proposed SNUR, because the three key TSCA duties attach at different moments. Getting the sequence wrong leads either to missed export notices or to unnecessary import-certification work.

TSCA Section 5(a) SNUN Notice

The 90-day advance SNUN obligation reaches anyone intending to manufacture, import, or process a covered substance for the designated significant new use. It attaches only when the SNUR is finalized, not at proposal. There is nothing to file today under this provision.

TSCA Section 12(b) Export Notification (Live Now)

This is the obligation that is already active. Under 40 CFR 721.20, any person who exports or intends to export a covered substance on or after August 31, 2026 must comply with TSCA Section 12(b) export notification. It attaches at the proposal stage, before the rule is final. EPA estimates roughly $106 per notice. Note that August 31, 2026 is also the comment deadline, so this date should be circled twice. Teams handling trade and customs compliance should confirm export destinations for these substances now.

TSCA Section 13 Import Certification

Import certification under TSCA Section 13 applies only once the SNUR is final. Do not apply Section 13 certification duties from this proposal. Over-application here is the most common compliance error at the proposal stage, and it creates unnecessary work.

TSCA SNUR export notification and import certification timing for manufacturers

Click on image to view full

Compliance Costs Under the Proposed Rule

EPA published its own cost estimates in the notice. These figures matter for planning, because a single SNUN is a material expense that should be weighed against reformulation or supplier substitution.

SNUN costs are incurred only if a company decides to pursue a significant new use as defined in the rule. Export notification costs vary by the number of destination countries. Verified against the Federal Register economic impacts section and the docket at Regulations.gov.

Industries Most Exposed

The exposure in this batch is concentrated, which makes targeted screening efficient. Manufacturers in semiconductor and high-tech and electronics manufacturing carry the strongest exposure.

Semiconductor and Electronics (Highest Relevance)

Tertiarybutylarsine (P-25-77) is an MOCVD arsenic precursor central to compound semiconductor epitaxy. P-25-126 and P-25-127 are photoresist salts flagged as potential PBT substances and designated import-only, with PPE and enclosed-processing requirements. P-25-25 is a photolithography intermediate carrying a carcinogenicity concern. Any deviation from the Order conditions for these substances is precisely what would constitute the significant new use.

Coatings, Inks, and Polymers

Two turbostratic graphene grades (P-24-86, P-24-87) span coatings, inks, batteries, composites, and energy storage. The batch also includes an architectural paint additive (P-24-196) and a paving additive (P-25-15). For inhalation exposure, the graphene Orders require a NIOSH-certified respirator with an assigned protection factor of at least 50, rising to 1,000 for spray application or higher-concentration formulations.

Polyolefins, Fragrance, and Industrial Cleaning

Two pyrophoric zirconium and aluminoxane catalyst systems (P-21-7, P-21-8) affect polyolefin production. Fragrance and personal care are touched by P-21-36 and P-21-185, and industrial cleaning by the P-24-27 surfactant. Teams managing chemical and hazmat compliance across these categories should map each substance to affected SKUs.

TSCA SNUR covered substances mapped to affected manufacturing industries

Click on image to view full

Reporting, Documentation, and BOM Screening Challenges

The practical challenge is not the legal text. It is knowing whether any of these 14 substances sits somewhere in a multi-tier supply chain, often several tiers below the finished product. This is a substance-to-BOM mapping problem, and spreadsheets do not scale to it.

Compliance teams face three recurring difficulties. First, identifying whether a covered PMN substance appears in a supplier's formulation when many identities are confidential business information. Second, validating supplier certificates and safety data sheets at the volume a global portfolio requires. Third, maintaining continuous audit-ready documentation so that a point-in-time record exists if EPA or a customer asks what you knew and when.

A centralized compliance data backbone addresses this by holding every substance declaration, threshold, and supplier response in one queryable system. That is what lets a team answer, in minutes rather than weeks, which finished products contain a specific high-risk substance.

Compliance Risks and Enforcement Exposure

TSCA carries significant civil penalties for violations, and the risk here is not only federal. It is also commercial. Consider how each audit type interacts with a proposed SNUR.

• Regulatory inspections: EPA can review whether required Section 12(b) export notices were filed once the August 31, 2026 trigger passes. This obligation is live regardless of finalization.

• Customer audits: OEMs increasingly require documented substance disclosures. A gap in your SNUR screening can surface during a customer audit long before EPA acts.

• Certification audits: ISO 14001 and IATF 16949 surveillance often probe chemical management controls and regulatory change tracking.

No software makes an organization audit-proof. The objective is to be audit-ready, which means reducing surprises and cutting the hours needed to assemble an evidence pack. Strong evidence integrity records who submitted a declaration, when it was submitted, and under what authority. If you want a fast benchmark of your current state, you can book a compliance risk assessment to see where documentation gaps exist across TSCA, PFAS, and related frameworks.

Recommended Compliance Actions

The following steps prioritize the obligations that are live now and the substances with the highest exposure.

1. Screen BOMs against the 14 PMN numbers now. The list is complete and does not require the docket to develop further. Prioritize the four semiconductor and electronics substances.

2. Check export exposure before August 31, 2026. Section 12(b) applies to exports on or after that date for all 14 substances. Confirm destination countries and prepare notices where needed.

3. Do not apply Section 13 import certification yet. These duties attach only on finalization. Applying them now wastes effort.

4. Assess whether to comment. The comment window closes August 31, 2026. Any organization using a covered substance in a way that might fall outside the Order restrictions should weigh submitting comments.

5. Confirm Order conditions for the import-only photoresists. For P-25-126 and P-25-127, verify with suppliers that PPE and enclosed-processing conditions are met, since deviation is exactly what would constitute the significant new use.

6. Map each substance to affected SKUs and plants. Use proactive compliance risk management so exposure is visible by product, supplier, and region.

How AI Automates TSCA SNUR Compliance

Chemical rulemaking moves faster than manual tracking can follow. EPA has now published multiple SNUR batches in 2026 alone. Watching every batch, extracting the covered substances, and cross-checking them against a live BOM is exactly the kind of high-volume, repeatable work that automation handles well.

Certivo functions as a system of record for product compliance, with CORA as the embedded intelligence layer. CORA-powered regulatory intelligence monitors new SNUR proposals and other TSCA actions, then flags whether any covered substance appears in your product data. This is the horizon-scanning capability that turns a Federal Register notice into a specific, actionable list of affected SKUs.

On the documentation side, AI document parsing reads supplier safety data sheets and certificates, extracts substance and threshold data, and validates it against the covered list. This is the same approach Certivo uses to manage large chemical inventories, described in how AI automates TSCA Section 8(a)(7) PFAS compliance. The result is a shift from reactive scrambling at each deadline to continuous readiness. For a complete view of the platform approach, see the guide to product compliance management for global manufacturers.

Executive Conclusion

The EPA TSCA SNUR proposed in 2026 is a focused rule with one time-sensitive edge. The Section 12(b) export-notification obligation is live for exports on or after August 31, 2026, while the SNUN and Section 13 import duties wait for finalization. The substances with the most weight sit in semiconductor, electronics, coatings, and polymer supply chains.

For a $10B manufacturer, the practical risk is not the rule itself. It is not knowing whether one of these 14 substances is buried in a supplier formulation somewhere in the portfolio. That is a data problem, and it is solvable with substance-level BOM screening and continuous regulatory intelligence. To map your exposure across products and suppliers before finalization, speak with a compliance specialist.