Carbon Nanotubes Require Toxic Substances Control Act (TSCA) Registration
Last week, U.S. EPA issued a notice on the TSCA inventory status of Carbon Nanotubes (CNT). EPA generally considers CNTs to be chemical substances distinct from graphite or other allotropes of carbon listed on the TSCA inventory. Many CNTs may therefore be new chemicals under TSCA section 5.
EPA has taken steps to inform manufacturers that CNTs may require notification under TSCA section 5. EPA has made numerous public statements and responses to written inquiries indicating that CNTs are not necessarily identical to graphite or other allotropes of carbon.
Manufacturers have been encouraged to submit a bona fide intent to manufacture or import, to submit a notice under TSCA section 5. If a particular CNT is not on the TSCA Inventory, anyone who intends to manufacture or import that CNT is required to submit a PMN (or applicable exemption) under TSCA section 5 at least 90 days before commencing manufacture.
Source: EPA Notice