The TSCA SNUR 2026 final rule (91 FR 31962), signed May 26, 2026 and effective July 28, 2026, adds Significant New Use Rules for 35 chemical substances under the Toxic Substances Control Act. Each substance was the subject of a premanufacture notice (PMN) and is already covered by a TSCA Section 5(e)(1)(A) Order. If your organization manufactures, imports, or processes any of these 35 substances for a use EPA has designated as significant and new, you must notify EPA at least 90 days before that activity begins.

This guide explains what the rule requires, which industries it touches, how the exemptions differ substance by substance, and how compliance teams can manage the underlying data at scale. If you want to know where your product portfolio and supplier base stand against restricted-substance rules like this one, you can request a compliance risk assessment to map your exposure before the effective date.

Key Takeaways

📌 EPA finalized TSCA SNUR 2026 for 35 PMN substances at 40 CFR 721.12184 through 721.12218, all tied to existing TSCA Section 5(e)(1)(A) Orders.

⏳ The rule is effective July 28, 2026. A significant new use triggers a mandatory 90-day advance Significant New Use Notice (SNUN) before activity can start.

📄 Because this is a final rule, TSCA Section 13 import certification and TSCA Section 12(b) export notification apply from the effective date, with no further finalization step.

⚠️ Article exemptions are not uniform. Five different exemption conditions apply across the batch, and roughly a third of the substances carry no exemption at all.

🏭 Nine substances are semiconductor photoresist and microlithography chemistries, several import-only, with two carrying an 18-month manufacturing limit.

📊 SNUN submission costs run about $45,000 for large businesses and $14,500 for small businesses, including a $37,000 user fee ($6,480 reduced), with a 30 to 170 hour reporting burden.

🤖 The practical challenge is data. Matching 35 PMN identifiers against supplier declarations and bills of material is where compliance automation and BOM-level intelligence reduce risk.

What Is the TSCA SNUR 2026 Final Rule

A Significant New Use Rule (SNUR) is issued under TSCA Section 5(a)(2). It lets EPA designate specific uses of a chemical as "significant new uses," which then require advance notice to the agency. The TSCA SNUR 2026 rule finalizes SNURs for 35 substances that already carry TSCA Section 5(e)(1)(A) consent Orders. Those Orders were put in place because EPA determined, absent sufficient information for a reasoned evaluation, that the substances may present an unreasonable risk to health or the environment.

The rule identifies any manufacturing, processing, use, distribution, or disposal that does not conform to the underlying Order as a significant new use. In plain terms, the SNUR locks in the Order's protective conditions and makes departure from them a reportable event. You can review how this fits the wider federal chemical framework on Certivo's TSCA framework page.

Core Facts at a Glance

TSCA SNUR 2026 final rule overview for 35 new chemical substances compliance

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Which 35 Chemical Substances Are Covered

The 35 substances span several distinct chemistry families. Grouping them by application is the fastest way for a compliance team to decide whether the rule touches its supply chain.

Semiconductor and Microlithography Chemistries

Nine substances are photoresist, photoacid-generator, and related microlithography chemistries used in semiconductor manufacturing (P-24-185, P-25-28, P-25-3, P-25-4, P-25-16, P-25-20, P-25-21, P-25-67, and P-24-189). EPA applied its heaviest controls here. Several are import-only, and two (P-24-185 and P-25-28) may not be manufactured for longer than 18 months. Their exemptions apply only once the substance is reacted or adhered onto a semiconductor wafer surface during photolithography. Fabs and their chemical suppliers should treat this group as the priority screen. Certivo's semiconductor and high-tech industry page outlines the broader material-compliance picture for this sector.

Adhesives, Sealants, Coatings, and Isocyanates

A large share of the batch is polyol-ether, isocyanate, and polyurethane chemistries used in adhesives, sealants, coatings, and industrial curatives (the P-22-60 through P-22-67 family, plus P-23-32, P-24-85, P-24-102, and P-24-103). Most carry a "completely reacted, cured, or incorporated into a polymer matrix" condition. If your formulations use these classes of reactive intermediates, the chemical and hazmat compliance solution is the relevant starting point.

Batteries, Flame Retardants, and Other Categories

The remaining substances cover targeted applications: a sealed-battery and supercapacitor additive (P-18-413), a battery-manufacturing component (P-23-173), a thermoplastic flame retardant (P-18-104), a zinc-nickel electroplating additive (P-21-215), two laundry fragrance ingredients with concentration caps (P-23-9 at 0.1 percent and P-23-10 at 1 percent), a fuel additive (P-24-79), a 3D-printing ink cartridge additive imported only (P-24-82), and a wind-blade repair adhesion promoter (P-22-153). This spread is why a single BOM screen against all 35 PMN identifiers is more reliable than assuming the rule sits in one industry.

TSCA SNUR 2026 chemical substance groups organized by affected manufacturing industry

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What Compliance Obligations the SNUR Triggers

The rule creates one primary duty and two pre-existing duties that switch on at the effective date.

The 90-Day SNUN Requirement

Anyone intending to manufacture, import, or process one of the 35 substances for a designated significant new use must submit a Significant New Use Notice at least 90 days beforehand. The activity cannot begin until EPA reviews the notice, makes its TSCA Section 5(a)(3) determination, and takes any required action. This duty binds manufacturers, importers, and processors, not only the original PMN holder. That distinction matters because downstream formulators and importers are frequently unaware they are in scope.

Import Certification and Export Notification

Because this is a final rule, two requirements apply from July 28, 2026 with no waiting period. Importers must certify under TSCA Section 13 that shipments comply with all applicable TSCA rules and Orders. Exporters must file a one-time export notification under TSCA Section 12(b) for the first export to each country, at roughly $106 per notification. Teams managing cross-border flows can align these duties through the trade and customs compliance solution.

SNUN Costs and Reporting Burden

These figures reflect the fees known at the time of the rulemaking. The practical takeaway is that an accidental significant new use is expensive to remediate, so early screening is far cheaper than a reactive filing.

Article Exemptions Vary by Substance

This is the single most important operational point in the rule. There is no blanket article exemption across the batch. Assuming a finished product relieves the obligation is the most common way teams get this wrong. Five distinct conditions apply.

The "cured or reacted" condition is legally distinct from a standard article exemption. It is keyed to chemical reaction completeness, not to physical incorporation into a manufactured article. For the seven substances with no exemption, incorporation into a downstream product does not by itself relieve the significant-new-use restrictions. This is where BOM-level compliance tracking earns its place, because the exemption logic has to be resolved per substance, per product.

TSCA SNUR 2026 exemption categories reference card for restricted substance compliance

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Industries and Supply Chains Affected

Because obligations bind processors and users, the reach extends past the original manufacturers. The most exposed sectors are semiconductor and microlithography, adhesives and sealants, batteries and supercapacitors, plastics and flame retardants, electroplating, fragrance and consumer products, fuel additives, 3D printing, and wind energy. Any importer, distributor, or downstream formulator handling these substances in bulk, in a mixture, or in an article can fall in scope. Electronics and battery supply chains are a particular focus given the semiconductor group, and Certivo's electronics manufacturing industry page covers the wider material-disclosure demands these buyers face.

Compliance Risks and Enforcement Exposure

The core risk is inadvertent non-compliance. A processor or importer that begins a designated significant new use without filing a SNUN is in violation from the moment the activity starts, and TSCA carries civil and criminal penalties for such violations. A second risk is import-certification failure, since every affected shipment must be certified from the effective date. A third is the exemption trap described above, where a team assumes a cured, destroyed, or article-incorporated status that does not actually apply to that substance.

No software eliminates enforcement risk or guarantees a clean inspection. The realistic objective is to be audit-ready, to reduce surprises, and to shorten response time when a regulator, customer, or certification body asks for evidence. Maintaining audit-ready documentation across frameworks with time-stamped, point-in-time records is what supports that during an EPA inspection or a customer audit.

Timeline and What Happens Next

Based on currently available regulatory guidance, EPA continues to issue SNUR batches on a rolling schedule, and photoresist and semiconductor chemistries have drawn consistent scrutiny across recent batches. Manufacturers should expect further SNURs on related chemistries and should build a repeatable screening process rather than treating each batch as a one-off. Certivo's full frameworks library tracks these developments across jurisdictions.

TSCA SNUR Compliance Checklist

✅ Screen supplier substance lists and any planned production or import activity against all 35 PMN numbers, prioritizing the nine microlithography entries.

✅ For each identified substance, confirm which exemption category applies before assuming a finished product relieves the obligation.

✅ Treat TSCA Section 13 import certification and Section 12(b) export notification as binding from July 28, 2026.

✅ Flag P-24-185 and P-25-28 for their 18-month manufacturing limit, and route the full photoresist group to wafer-fab supply chains.

✅ If using fragrance ingredients P-23-9 or P-23-10, confirm formulations stay within the 0.1 percent and 1 percent caps.

✅ File any SNUN well ahead of the intended activity, since the 90-day clock runs from EPA's receipt of the notice.

How AI and Automation Support TSCA SNUR Compliance

The hardest part of a rule like this is not reading it. It is answering a simple question at scale: do any of my products, formulations, or incoming shipments contain these 35 substances, and if so, which exemption applies. For a large manufacturer with tens of thousands of parts and hundreds of suppliers, that is a data problem, not a legal one.

This is where Certivo functions as a compliance data backbone. It maps supplier declarations and safety data sheets to specific parts and bills of material, so a new SNUR becomes a query against structured data rather than a manual spreadsheet exercise. AI-powered document parsing and certificate validation extracts substance and CAS data from supplier documents and flags gaps at intake, which is the same capability teams rely on for PFAS supplier data collection at scale.

CORA-powered regulatory intelligence adds the horizon-scanning layer. It monitors new SNUR batches and related TSCA actions and maps them to the parts and SKUs they affect, so compliance teams learn about a change before it becomes an exposure rather than after. Combined with proactive compliance risk management and supplier documentation workflows, this shifts the team from reactive filing toward continuous readiness. The same approach that Certivo uses to automate TSCA Section 8(a)(7) PFAS reporting across 12,000 substances applies directly to screening a 35-substance SNUR batch.

Executive Conclusion

The TSCA SNUR 2026 final rule is narrow in scope but sharp in consequence. Thirty-five substances, one 90-day notice duty, and a set of exemptions that differ from one substance to the next. For a global manufacturer, the exposure rarely comes from the original chemistry maker. It comes from a downstream formulator, importer, or distributor that never realized a substance in its supply chain was covered. The organizations that manage this well are the ones that can screen a new batch against structured BOM and supplier data in hours, not weeks.

To understand where these 35 substances and other restricted-substance rules sit in your product portfolio and supplier base, you can request a compliance review and map your exposure before the July 28, 2026 effective date.