Not just an environmental thing1
In the evolution of international chemical control laws, knowing where your products are going, and whether those products or their components are regulated in the myriad of jurisdictions they cross, is developing into an imperfect science of conjecture. While somewhat late to the game, in 2016, the United States finally adopted an update to its over 30-year-old chemical control legislation. Many companies are scrambling to determine whether the Toxic Substances Control Act (TSCA), as revised by the Frank R. Lautenberg Chemical Safety for the 21st Century Act (the “new TSCA” or Lautenberg)is going to have an impact on their multinational supply chain obligations. Chemical processors (often Toll Manufacturers), who had long presumed their manufacturer-customers would assure their downstream TSCA compliance, are now asking for formal assurances of compliance. Raw material suppliers are facing customer demands for broad certifications of compliance with all countries’chemical inventories, including verifying consistent identities for commodities they supply globally. And even articles importers are demanding universal chemical registration/notification/exemptions from those supplying the chemical components in their articles.