EPA's newest TSCA SNUR compliance obligation is now live. On May 22, 2026, the U.S. Environmental Protection Agency published a final rule, "Significant New Use Rules on Certain Chemical Substances (25-1.5e)," at 91 FR 30226. The rule became effective on July 21, 2026, and it establishes significant new use rules for 29 chemical substances tied to existing TSCA section 5(e) consent orders. For manufacturers, importers, and processors, this is not a proposal to monitor. It is an enforceable requirement that binds any company touching these substances, not only the original premanufacture notice submitters.

Book a compliance risk assessment to understand where these 29 substances may sit inside your supply chain before you commit to new supply agreements.

Key Takeaways

📌 EPA finalized SNURs for 29 chemical substances under TSCA section 5(a)(2), effective July 21, 2026, extending section 5(e) order restrictions to the entire market.
⏳ Any activity designated a significant new use requires a Significant New Use Notice (SNUN) filed at least 90 days before that activity begins.
🏭 Chemical manufacturing, semiconductors, batteries, adhesives, lubricants, detergents, and downstream formulators are all in scope.
⚠️ SNUN submissions cost roughly $45,000 for large businesses and $14,500 for qualifying small businesses, with 30 to 170 hours of burden per filing.
🔗 Import certification (TSCA section 13) and export notification (TSCA section 12(b)) both apply as of the July 21, 2026 effective date.
📄 Article and cured/reacted exemptions vary substance by substance, so incorporation into a finished product does not automatically relieve obligations.
🤖 Screening by PMN number and supplier engagement, not CAS matching alone, is required because many identities are generic or CBI-protected.

What the TSCA SNUR Final Rule Requires

A significant new use rule under the Toxic Substances Control Act does one thing with large consequences. It takes the restrictions EPA placed on a single company through a section 5(e) consent order and extends them to everyone. Under this rule, any manufacturing, processing, use, distribution in commerce, or disposal that does not conform to the underlying order is designated a significant new use.

The obligation that follows is the SNUN. If you intend to manufacture, which by statute includes import, or process any of these 29 substances for a designated significant new use, you must notify EPA at least 90 days before starting. You cannot begin until EPA reviews the notice, makes a section 5(a)(3) determination, and takes any required action. This structure sits alongside the broader TSCA framework that already governs new and existing chemicals in the United States.

Which Substances Are Covered

The rule finalizes 29 substances at 40 CFR 721.12112 through 721.12114 and 721.12121 through 721.12146. Six substances originally proposed in November 2025 (PMNs P-22-95 through P-22-100) were not finalized. EPA stated it received new information requiring further review and will address them separately, so these should be tracked as a pending future action rather than treated as resolved.

Several identities are public, including CASRNs such as 2267262-12-2, 2337348-25-9, and 15499-84-0. Many others are generic or protected as Confidential Business Information, with only an accession number and a PMN identifier. That detail matters operationally. You cannot screen this batch reliably by CAS number alone. Effective BOM substance and threshold management here depends on matching by PMN number through direct supplier engagement, a capability that spreadsheet-based programs struggle to deliver at scale.

TSCA SNUR compliance workflow showing 90-day SNUN notification before new chemical use

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Who Is Bound and What It Costs

The rule applies to manufacturers, importers, and processors. EPA cites NAICS 325 (chemical manufacturing) and 324110 (petroleum refineries) as illustrative, not exhaustive. Because SNUR obligations bind processors and downstream users, distributors and formulators using affected materials can also fall in scope.

The cost of a SNUN is significant. EPA estimates roughly $45,000 per submission for large businesses and $14,500 for qualifying small businesses. These include a user fee of $37,000, reduced to $6,480 for eligible small firms under 40 CFR 700.45. Preparation burden runs between 30 and 170 hours per submission. For companies evaluating chemical and hazmat compliance exposure, these figures make early screening far cheaper than a reactive filing during a live sourcing decision.

Article and Cured Exemptions Vary by Substance

There is no blanket exemption across this rule. Each substance must be screened individually, and the exemption category determines whether building the substance into a product relieves the ongoing restriction.

This variability is where audit exposure hides. A team that assumes a uniform article exemption across the batch will misjudge obligations on the substances that carry only a cured-resin, battery-sealed, or no exemption at all. Mapping each identity to its specific carve-out is the kind of BOM-level compliance work that has to be tracked at the part level, not the company level.

Industries in Scope

While EPA names only two NAICS sectors, the substance profiles reach much further. Semiconductor and photolithography operations are directly affected through two photoresist chemistries. Battery manufacturing is implicated by a sulfamide fluorophosphate salt exempted only when sealed inside a cell. Adhesives, sealants, resins, and coatings appear through multiple polymer and reacted or cured substances. Lubricants, asphalt and road materials, tin chemistry, and dye and pigment producers each map to specific entries.

Downstream users deserve particular attention. Because the rule binds processors and users, an importer or formulator that incorporates an affected substance without confirming the exemption status can inherit the obligation. This is why semiconductor and high-tech, electronics manufacturing, and chemical manufacturing teams should treat this rule as a supply-chain screening exercise rather than a purely internal one.

Industries affected by the 2026 TSCA SNUR final rule for 29 chemical substances

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Semiconductor and Battery Provisions to Watch

Two entries carry an unusual condition that supply-chain planners should flag now. The iodonium salt (P-24-160) and the aromatic sulfonium salt (P-24-190), both photoresist chemistries, designate it a significant new use to manufacture the substance for longer than 18 months. Both are also exempt only once reacted or adhered onto a semiconductor wafer, and both restrict import to solution form or sealed containers of 5 kilograms or less. The 18-month manufacturing limit is atypical and could affect long-term supply continuity from a single production run.

A separate detail worth noting is a molecular-weight trigger on one substance (P-23-134), where manufacturing at 10,000 Daltons or greater is itself a significant new use. Details like these reward multi-tier supply chain transparency, since the trigger sits with the manufacturer several tiers upstream, not with the brand at the top.

Import and Export Obligations Now in Force

Because this is a final rule, two pre-existing TSCA mechanisms are triggered as of the July 21, 2026 effective date. Under TSCA section 13, chemical importers must certify that shipments comply with all applicable TSCA rules and orders, referencing 19 CFR 12.118 through 12.127 and 40 CFR part 707, subpart B. Under TSCA section 12(b) and 40 CFR 721.20, any person exporting or intending to export these substances must file a one-time export notification per country of first export, at roughly $106 per notification.

For companies with global flows, this places SNUR screening squarely inside trade and customs compliance rather than in a separate chemical silo. Confirm with affected suppliers whether they are exporting on or after the effective date, and align import certification language accordingly.

Reporting and Documentation Challenges

The practical difficulty is not understanding one substance. It is screening thousands of parts and raw materials against 29 generic or CBI-protected identities, then proving the result if a customer or regulator asks. SNUNs are filed on EPA Form 7710-25 through e-PMN software under 40 CFR 720.40 and 721.25. Recordkeeping obligations under 40 CFR 721.125 vary by entry, most commonly paragraphs (a) through (i) and (k), with narrower ranges for the enzyme and certain article-exempt substances.

A compliance engineer preparing for a customer audit, an EPA inspection, or an ISO 14001 certification audit needs point-in-time evidence: which materials were screened, against which PMN list, on what date, and with what supplier attestation. That is a data versioning problem best solved with continuous audit-ready documentation and time-stamped declarations, not an email archive. No software makes an organization audit-proof. The realistic objective is to be audit-ready, reducing surprises and shortening response time from days to hours.

Compliance Checklist

✅ Screen new-chemistry supply, trial materials, and planned production changes against the 29 PMN numbers before signing supply agreements.
✅ For each identified substance, confirm the specific exemption category (full article, conditional, cured or reacted, or none).
✅ Flag the two semiconductor photoresist substances (P-24-160, P-24-190) for wafer-fab supply chains, including the 18-month manufacturing limit.
✅ If using the polysaccharide lyase enzyme (P-23-127) in detergents, build the required heat deactivation step (65°C or greater for at least 10 minutes) into wastewater handling.
✅ Confirm whether suppliers are exporting on or after July 21, 2026, and align TSCA section 12(b) and section 13 obligations.
✅ Track the six deferred PMNs (P-22-95 through P-22-100) for a separate future SNUR action.

How AI Reduces the SNUR Screening Burden

Manual SNUR screening does not scale. When identities are generic and matching must occur by PMN number through supplier outreach, the work multiplies across every tier. This is where AI-native compliance automation changes the economics. Certivo functions as a centralized compliance data backbone that holds product, BOM, and supplier records in one system, so a new rule can be screened against the entire portfolio rather than one part at a time.

Certivo's automated supplier data collection portals let suppliers respond to targeted PMN-based requests instead of open-ended spreadsheets, and AI document parsing and certificate validation extracts and checks the responses at intake. CORA-powered regulatory intelligence monitors the docket, including the six deferred PMNs, so horizon scanning happens before an obligation lands rather than after. The result is a shift from reactive filing to proactive compliance risk management.

If your team is screening this rule against a large BOM today, request a compliance review to see how Certivo maps substance obligations to specific parts and suppliers.

Executive Conclusion

The 2026 TSCA SNUR final rule is a reminder that new-chemical regulation now reaches the entire market, not just the first submitter. Strong TSCA SNUR compliance depends on three disciplines: screening by PMN number rather than CAS alone, confirming the exemption category for each substance, and holding point-in-time evidence that a customer or regulator will accept. Companies that rely on manual processes will feel this most in the substances with narrow or absent exemptions and in the import and export certifications that took effect on July 21, 2026.

The organizations that absorb rules like this without adding headcount are the ones that treat compliance as a continuous, data-driven function. To see how Certivo supports that shift, speak with a compliance specialist.