EPA Risk Questions for Importers

A 12-point self-assessment for US importers and distributors. Find out where your supply chain stands on TSCA compliance.

Common Risk Questions

These are some of the TSCA compliance gaps an audit looks for in importer supply chains.

Do you have current SDS for every imported chemical product?
Are your TSCA Section 13 import certifications up to date?
Have you screened for the 5 regulated phthalates under TSCA §6?
Do you have PFAS reporting documentation per TSCA 8(a)(7)?
Are your suppliers providing test certificates for chemical content?
An audit covers these and more

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Why This Checklist Matters

EPA Enforcement Trend

EPA enforces TSCA import certification and reporting rules against chemical importers, and civil penalties can apply to violations.

Many importers believe they are compliant because they have some documentation on file. Gaps can still appear around PFAS reporting, supplier verification, and phthalate testing for reformulated products.

This checklist gives you a quick way to identify your biggest exposure areas before you invest in a full audit.

Need More Than a Checklist?

Typical audit range is $3,500 to $7,000, quoted per project.

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