The Biobased and Renewable Products Advocacy Group (BRAG) helps members develop and bring to market their innovative biobased and renewable chemical products through insightful policy and regulatory advocacy. BRAG is managed by B&C® Consortia Management, L.L.C., an affiliate of Bergeson & Campbell, P.C.
EPA Issues SNURs For Several Biobased Chemicals
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On May 8, 2015, the U.S. Environmental Protection Agency (EPA) issued a direct final rule for 25 chemical substances that were the subject of premanufacture notices (PMN), including several biobased chemical substances. The rulemaking under Section 5, known as a significant new use rule or SNUR, requires persons who intend to manufacture (including import) or process any of these 25 chemical substances for an activity that is designated in the SNUR as a significant new use to notify EPA at least 90 days before commencing that activity. The required notification provides EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity before it occurs. The rule will be effective July 7, 2015.

Bergeson & Campbell, P.C. (B&C®) has posted an analysis of the restrictions and testing included in the SNURs for the biobased chemicals.