The United States Environmental Protection Agency (EPA) has published updated rules of the Toxic Substances Control Act (TSCA) Section 6 (h), in order to ban among others, the processing and distribution of certain uses of phenol, isopropylated phosphate (3:1) (PIP 3:1). Because of the far-reaching consequences regarding PIP 3:1, EPA has provided a No Action Assurance that currently extends the compliance date for this chemical until March 8, 2022. A proposed rule, which is still under consideration, seeks to further extend the compliance date until October 31, 2024.
We keep monitoring the situation in order to respond to requirements and effects on risk management resulting from the TSCA regulations. For this reason, we would like to inform you of the current status and the position of our company in the supply chain.
BRAND is a downstream processor and distributor of finished products made of plastics (polymers) and glass. We are already in close and permanent contact with our raw material suppliers about the situation and ask them to issue corresponding conformity certificates in a timely manner where required. The responses we have received from our suppliers so far do not indicate that any of the 5 substances restricted under TSCA Section 6 (h), are contained in our products. However, it is not yet possible to make a conclusive statement, as some responses are still pending. We will pass on the relevant information to our customers as soon as it is available.
For further questions please do not hesitate to contact us (firstname.lastname@example.org).
Wertheim, December 6, 2021
BRAND GMBH + CO KG