Background
Advancing Chemical Innovation Through Smart Regulation
Chemical innovation forms the foundation of most products in society and is key to a growing, vibrant, and sustainable economy, including job creation.
ACI supports a risk-based regulatory approach for the Environmental Protection Agency’s (EPA) chemical management process that is practical, timely, and firmly grounded in sound science. This ensures member companies can formulate new innovative products for American consumers. We remain committed to a transparent and effective implementation process that enables meaningful stakeholder engagement, relies on the best available scientific data, and reflects real-world conditions across the chemical value chain.
Why It Matters
Ongoing Challenges with TSCA Implementation
Signed into law by President Barack Obama, the Frank L. Lautenberg Chemical Safety Act for the 21st Century [P.L. 114-182] represents a bipartisan compromise and a critical update to the Toxic Substances Control Act (TSCA). However, its implementation has faced growing challenges. In recent years, ACI and its partners have raised concerns about EPA’s approach to new and existing chemical reviews. ACI member companies have reported significant delays in EPA’s ability to process Pre-Manufacture Notice (PMN) submissions within the 90-day statutory deadline, with some reviews taking multiple years.
These delays hinder the development and commercialization of next-generation chemistries that could otherwise use improved manufacturing and processing techniques that reduce risk, exposure, energy use, and environmental impact. In some cases, EPA has imposed overly conservative assumptions and data requirements that actively hamper the speed at which industry can release new safe and innovative products. Additionally, most new chemical PMN determinations have been regulated via Significant New Use Rules (SNURs), which often prohibit usage by downstream manufacturers with complex supply chains.
What's Next?
Protecting Innovation and U.S. Competitiveness
ACI has submitted letters to the EPA and committees of jurisdiction in both the House and Senate, outlining the importance of restoring statutory compliance and ensuring timely, science-based chemical reviews. ACI and our members have conducted multiple Capitol Hill fly-ins to advocate directly to Congress on these priorities.
ACI stands ready to work with Congress, EPA, and stakeholders to implement a chemical management process that supports American innovation, ensures safety, and benefits U.S. consumers and international business competitiveness.
Related Materials and Resources
- ACI Supports Science-Based Flexibility in EPA's TSCA Risk Evaluation Procedures [11/7/2025]
- Cleaning Products Industry Leaders Advocate to Maintain American Innovation Leadership [5/22/2025]
- Cleaning Products Industry Leaders Elevate Innovation on Capitol Hill [5/15/2025]
- ACI to OMB: Changes at EPA Can Protect and Foster Growth [5/14/2025]
- ACI to Congress: Encourage EPA to Clear “Bottleneck” to Chemical Innovation [1/22/2025]
- ACI to President-Elect Donald Trump, Congress: We Need “Robust” TSCA Implementation and Funding [1/16/2025]
- ACI Submits Comments Regarding Prioritization of Existing Chemical Substances Under TSCA [10/23/2024]
- Leading Cleaning Product Makers, Suppliers Advocate on Capitol Hill [6/13/2024]
- ACI Urges Senate Committee to Ensure EPA Abides by TSCA Obligations [1/24/2024]
- ACI Submits Comments to EPA on TSCA Fees [1/17/2023]
FAQ
Chemical innovation underpins a wide range of consumer products, including cleaning products, and plays a critical role in economic growth and job creation. Continued innovation helps improve cleaning product performance while reducing environmental impact.
ACI supports a risk-based regulatory framework that relies on sound science and real-world conditions. This approach helps ensure that chemicals are evaluated based on actual exposure and use patterns.
The Toxic Substances Control Act (TSCA) is the primary federal law governing chemical safety in the U.S. It was updated in 2016 through the Lautenberg Chemical Safety Act to strengthen EPA’s authority and modernize chemical oversight. The update aimed to improve safety reviews while maintaining a workable regulatory system.
ACI and its members have raised concerns about delays and inefficiencies in EPA’s New Chemical review process. Pre-Manufacture Notice (PMN) reviews frequently exceed the 90-day statutory deadline. These delays can stall innovation and prevent new cleaning products from reaching the market.
Extended review timelines can slow the development and commercialization of new cleaning products formulated by new chemistries. Over time, it can also discourage domestic R&D investments.
EPA’s New Chemical reviews have been unpredictable. In some cases, EPA has applied overly conservative assumptions and requests extensive data beyond statutory requirements. This can increase costs and prolong the approval process.
SNURs are regulatory tools used by EPA to restrict how a chemical can be used after review. While intended to manage risk, they can limit how downstream companies use approved chemicals, creating challenges for complex supply chains and reducing the practical utility of new chemistries.
Delays and regulatory uncertainty can make it more difficult for U.S. companies to compete globally. Other markets may provide faster, more predictable regulatory certainty. This can shift investment and technological advancement outside the United States.
ACI supports returning to statutory timelines and ensuring reviews are grounded in best available science. It also emphasizes transparency, stakeholder engagement and practical regulatory expectations.