TSCA compliance software, run from the substance master.

TSCA, substantially amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act in 2016, gives the EPA authority over industrial chemicals across their lifecycle. For most manufacturers, importers and processors, it comes down to five recurring duties.

On top of these sit substance-specific rules: risk management rules under section 6 for chemicals such as methylene chloride and trichloroethylene, the PBT rules, and the section 8(a)(7) PFAS reporting rule, whose submission window has been revised more than once. Check the EPA's current published dates before planning a PFAS submission.

TSCA obligations are not triggered by documents. They are triggered by facts about substances and how they move through the business, and those facts live in purchasing, production and sales systems, not in the regulatory folder.

• Import is manufacture. Importing a substance or a mixture makes you a manufacturer for TSCA purposes. A procurement decision to source a raw material from a new overseas supplier is a regulatory event, and it will not be logged as one.
• Volumes aggregate. CDR thresholds apply per substance per site per year. Getting that number right means summing receipts and production across ERP transactions, not asking a plant manager to estimate.
• Uses change quietly. A SNUR is triggered by a new use, not a new substance. Selling an existing product into a new application can be the trigger, and the commercial team will not know that.
• Inventory status changes. Active and inactive designations, and new listings, move. A substance that was fine to import last year may now require a notice.
• CBI is real. Much of the Inventory is confidential, generic names apply, and supplier confidentiality claims mean you may not know the actual identity of what you are buying without a formal request.

Worldover holds the substance, not the document, as the primary object. Every raw material, intermediate and finished mixture resolves to substances with CAS numbers, purities and supplier provenance. TSCA duties then become properties and queries on that graph.

• Inventory status on the substance. Listed, active, inactive or not listed, with the date checked and the source recorded, so a purchase of an unlisted substance is blocked before the PO is raised, not discovered at the port.
• New chemical workflow. Where a substance is not on the Inventory, Worldover opens the PMN track, assembles the data the notice needs from existing tox, use and exposure records, and holds the 90-day clock.
• SNUR screening on use change. Uses are recorded against substances and customers. Adding a use to a substance under a SNUR raises the notice requirement automatically.
• CDR aggregation. Production and import volumes are summed from actual transactions per substance per site per year, so each reporting cycle starts from a defensible number.
• Section 8 records. Adverse effects allegations, health and safety studies and substantial risk information are held against the substance with retention clocks, rather than in a shared drive.
• Willow agents. Willow monitors EPA rule changes, identifies the substances and products affected, and drafts the internal impact note and the filings for your regulatory lead to approve.

Companies selling into both the US and the EU run two regimes with different philosophies: REACH puts the registration burden up front by tonnage band, TSCA works from an existing Inventory with notices for new chemicals and new uses. The regulatory logic differs, but the data does not. Both need substance identity, composition, tonnage or volume, uses, and exposure information.

Worldover holds that data once. A new raw material is screened against the TSCA Inventory, the EU REACH registration status and the SVHC candidate list in the same step, and the obligations that follow are raised per market. Adding a market does not mean adding a parallel process.

Presperse, a US ingredient supplier serving major beauty brands, runs on Worldover for its substance master, regulatory documentation and customer-specific declarations. The same substance-first model is what makes US chemical obligations, from TSCA Inventory checks to Prop 65 warning logic, reportable rather than reconstructable.