On June 10, 2026, EPA proposed Significant New Use Rules (SNURs) for 19 new chemical substances under the Toxic Substances Control Act. For manufacturers, importers, and processors, TSCA SNUR compliance is now a live planning question, because this proposal would extend restrictions that currently bind only individual order-holders to the entire market. The rule is not yet final, and most obligations do not yet apply. But the substances span polyurethane, semiconductor photoresist, textiles, coatings, cement, oilfield, and consumer-product chemistries, so the screening work should begin now.

This guide explains exactly what EPA proposed, who would be bound and when, the thresholds involved, the full 19-substance list, and how to prepare without overreacting to a rule that has not been finalized.

If any of these chemistries appear in your formulations or bill of materials, you can request a compliance review to map your exposure before the rule advances.

Key Takeaways

📌 EPA proposed SNURs for 19 new chemical substances (new 40 CFR §§ 721.12260–721.12278) on June 10, 2026, under docket EPA-HQ-OPPT-2026-0499.

⚠️ The proposal would extend existing TSCA section 5(e) order restrictions to any manufacturer, importer, processor, or downstream user, not just the original PMN submitter.

⏳ The comment period closed July 10, 2026. As of this writing the rule is still proposed, so the SNUN and import-certification duties do not yet bind anyone.

📊 Obligations, once final, center on a 90-day advance Significant New Use Notice (SNUN), with EPA estimating $45,496 per submission for large businesses and $14,976 for small businesses.

🏭 Affected chemistries include spray polyurethane foam, semiconductor photoresist, textile softeners, coatings and inks, cement grinding aids, and consumer-product additives.

🔗 Because processors and downstream users would be covered, exposure is a multi-tier supply chain question, not just a manufacturer question.

🤖 The practical response is BOM-level substance screening and supplier data collection now, so that if the rule is finalized, controls are already in place.

What EPA Proposed

EPA proposed 19 SNURs for chemical substances that were each the subject of a premanufacture notice (PMN) and are already subject to a TSCA section 5(e)(1)(A) consent order. Those orders were issued after EPA determined, under section 5(a)(3)(B), that in the absence of sufficient information to permit a reasoned evaluation, the substances may present an unreasonable risk to human health or the environment.

A SNUR is not itself a risk determination or a ban. It is a notification mechanism. The proposal designates, as a significant new use, any manufacturing, processing, use, distribution, or disposal that does not conform to the restrictions in the underlying order. EPA's stated rationale is to hold all manufacturers and processors to the same standard as the original order-holder, not just the party that negotiated the order.

This is a single, homogeneous category. All 19 entries extend section 5(e) order terms market-wide. It is not a mixed batch of unrelated existing-chemical actions. For context on how EPA has been approaching new-chemical oversight, our overview of the TSCA compliance framework is a useful companion.

Who Would Be Bound, and When

This is the most important distinction for planning, and the one most likely to be misread. The rule is proposed, not final. That changes what applies today.

Significant New Use Notice (SNUN): Not Yet in Effect

If the proposal is finalized, any person intending to manufacture, import, or process any of the 19 substances for a designated significant new use would have to submit a SNUN to EPA at least 90 days before beginning that activity. Manufacture or processing could not start until EPA reviews the notice and makes a section 5(a)(3) determination. This duty attaches only on finalization.

Import Certification: Does Not Apply Yet

TSCA section 13 import certification (19 CFR 12.118 through 12.127; 40 CFR part 707, subpart B) attaches only once a SNUR is finalized. As a proposed rule, none of these 19 substances currently carry an import-certification obligation. Assuming otherwise would be a common and avoidable error.

Export Notification: Trigger Date Stated as July 10, 2026

The notice states that persons who export or intend to export a covered substance on or after July 10, 2026 are subject to TSCA section 12(b) export notification under 40 CFR part 707, subpart D. A one-time notice to EPA is required for the first export to a particular country, at an estimated $106 per notification. Exporters of these chemistries should confirm this obligation against the full notice before shipping.

TSCA SNUR compliance obligations before and after final rule for manufacturers

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The Industries Affected

The proposal reaches a wide set of industrial chemistries. Screening is easiest when organized by sector.

Because a SNUR, once final, would bind processors and downstream users and not only original manufacturers, any importer or distributor of formulations containing these substances is potentially in scope. Manufacturers in building materials and construction, electronics manufacturing, and semiconductor and high-tech should treat this as a formulation-level screening exercise. For chemistry-specific exposure, our chemical and hazmat compliance view maps substances to product lines.

The Full Batch: 19 Substances

For screening teams, the complete substance list is the most operationally useful part of this rule. The table below is drawn directly from the Federal Register text and includes the CFR section, PMN number, disclosed substance identity, risk basis, stated use, and the key threshold or condition for each entry.

A screening note that matters in practice: many of these substances are disclosed only by generic name, with no public CASRN or accession number. That means BOM matching often has to run against supplier declarations and safety data sheets rather than a clean identifier, which is the core reason substance-level screening here benefits from BOM-level material mapping rather than manual lookup.

Thresholds, Conditions, and PBT Candidates

Each order carries substance-specific protective measures. Several rest on numeric surface-water release limits expressed as parts per billion. For example, the two environment-only entries are P-24-6, with aquatic toxicity predicted above 316 ppb, and P-24-105, the polyurethane raw material, with aquatic toxicity predicted above 22 ppb. The P-24-105 order requires no consumer-product use, no surface-water release above 22 ppb, and a hazard communication program. These thresholds sit deep in formulations, which is exactly why continuous substance and threshold management matters here.

Three substances are flagged as potential PBTs: the biphenyl photoinitiator P-23-138 and the two photoresist components P-25-106 and P-25-107. EPA estimates environmental persistence beyond six months for these chemistries, consistent with heightened scrutiny of semiconductor photoresist materials. Wafer-fab supply chains should flag P-25-106 and P-25-107 for longer-term monitoring.

Exemptions are not uniform. A standard article exemption is confirmed for the two textile softeners P-21-166 and P-21-167, and a completely-reacted-or-cured exemption is confirmed for the spray-foam polyol P-23-78. Exemption status for several other entries, including P-24-105, could not be confirmed from the retrievable regulatory text, so no exemption should be assumed until the full codified language is checked.

Reporting, Documentation, and Audit-Readiness Challenges

For a compliance engineer, the operational challenge is not the rule text. It is proving, on demand, whether any of these 19 substances sit anywhere in a multi-tier supply chain, and at what concentration.

That is a documentation and data-versioning problem before it is a regulatory one. Screening against generic chemical names and confidential-business-information identifiers is difficult, since many substances here are disclosed only generically. This is where AI document parsing and certificate validation reduces manual review, extracting substance identity and concentration from supplier declarations and safety data sheets at scale.

Audit readiness matters across four distinct audit types, and each asks a different question:

• Internal audits: Can you demonstrate that screening covers current formulations and the June 10, 2026 cutoff date for ongoing uses?

• Customer audits (OEM-driven): Automotive and electronics OEMs increasingly expect supplier trust-center answers, similar to the self-service models used by Apple, Microsoft, and major automotive OEMs.

• Regulatory inspections: EPA and, for related chemistries, ECHA market surveillance expect time-stamped, point-in-time evidence.

• Certification audits: ISO 9001, IATF 16949, and ISO 14001 assessments expect evidence integrity.

Evidence integrity means recording who submitted a declaration, when it was submitted, and under what authority. Immutable audit logs, time-stamped declarations, and historic-state tracking let a team retrieve the exact compliance position for a product as it stood on a given date. No software makes an organization audit-proof. The realistic objective is to be audit-ready: to reduce surprises and shorten response time.

If you want a structured way to test this internally, the Customer Audit Readiness Scorecard covers documentation completeness across RoHS, REACH, Prop 65, PFAS, conflict minerals, and related frameworks, plus historic-state retrievability and hours-to-audit-pack response time.

Compliance Risks and Enforcement Exposure

The near-term risk is not an EPA penalty, because the rule is proposed. The real exposure is being unprepared if it finalizes, and being unable to answer customer and internal questions in the meantime.

⚠️ Market-access risk: Once final, manufacturing or processing for a significant new use without a SNUN would violate TSCA section 5.

⚠️ Downstream risk: Processors and users, not only manufacturers, would be bound, so a formulation change by a supplier could pull you into scope.

📄 Documentation risk: If you cannot show where these substances are, you cannot certify their absence to customers.

Continuous compliance risk monitoring is the practical hedge, so that a proposed rule becomes a tracked signal rather than a fire drill at finalization.

Supply Chain and Operational Impact

The extension of order terms to the whole market is what makes this a supply-chain problem. A substance that was previously one supplier's controlled input can now become a screening obligation for everyone who touches it downstream.

Multi-tier supply chain transparency is the core requirement. Tier 1 suppliers must be able to answer whether Tier 2 and Tier 3 inputs contain any of the 19 substances. Standardized supplier questionnaires and self-service supplier documentation reduce the friction of collecting that data, and give smaller suppliers a guided path rather than a complex spreadsheet.

Timeline and Enforcement Outlook

Based on currently available regulatory guidance, EPA typically takes several months to more than a year between a SNUR proposal and a final rule. A final rule for 26-1 is not expected imminently, so the docket should be monitored rather than acted on as if binding.

Compliance Preparation Checklist

1. Screen your BOMs now. Flag the four polyurethane precursors (P-24-105, P-23-78, P-24-16, P-24-70) and any other listed chemistry against current supplier data.

2. Confirm whether a comment was filed. The window closed July 10, 2026; verify internally if your team submitted comments.

3. Watch the docket. Monitor EPA-HQ-OPPT-2026-0499 for the final rule; do not assume import certification applies yet.

4. Verify P-24-105 water limits with suppliers. Confirm any release limit near the 22 ppb aquatic-toxicity threshold, and whether an exemption applies.

5. Flag the PBT candidates. Track P-23-138, P-25-106, and P-25-107 for longer-term monitoring, especially in semiconductor and coatings chains.

6. Confirm the export-notice trigger. If you export any of the 19 substances, verify the July 10, 2026 date against the full notice.

How AI and Automation Support TSCA SNUR Readiness

Spreadsheet-based screening does not scale to 19 generically named substances across thousands of parts and suppliers. The most effective approach treats a proposed rule as a monitored signal wired directly into product data.

Certivo functions as a compliance data backbone, mapping substances to specific parts and products so that a proposed SNUR becomes a targeted screening query rather than a manual hunt. CORA-powered regulatory intelligence tracks new-chemical actions and maps them to affected SKUs, supporting regulatory horizon scanning. CORA-enabled analysis then parses supplier declarations and certificates to validate substance identity and concentration, reducing manual data entry. The result is a shift from reactive compliance to continuous, audit-ready documentation.

For a sense of how this operates at scale, our explanation of how Certivo manages compliance across large substance lists and multi-tier supply chains applies directly to this kind of new-chemical monitoring.

TSCA SNUR compliance screening workflow from supplier data to BOM-level reporting

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If you want to see where these chemistries sit in your own portfolio, you can request a compliance review and start with a targeted BOM screen.

Executive Conclusion

TSCA SNUR compliance for the 26-1 batch is, for now, a preparation exercise rather than a live obligation. The rule is proposed, the comment period has closed, and no final rule has published. The strategic move is to screen bills of materials against the 19 substances today, confirm supplier positions on the key thresholds, and monitor the docket, so that if the rule is finalized, controls and evidence are already in place.

The organizations that handle this well will not treat it as a one-off. They will treat every new-chemical action as a signal to be mapped against product data automatically. To evaluate your exposure across these chemistries and build audit-ready documentation, speak with a compliance specialist.