Reporting Requirements for the TSCA Mercury Inventory

On October 26 2017, EPA published a proposed rule to require reporting from persons who manufacture (including import) mercury or mercury-added products, or otherwise intentionally use mercury in a manufacturing process.  The reporting rule is required by the amended Toxic Substance Control Act (TSCA) to help assist EPA in publishing an inventory of mercury  supply, use, and trade in the United States before April 1, 2017 and every three years thereafter. EPA published the first inventory in March 2017.  Based on the information collected, TSCA further directs EPA to identify any manufacturing processes or products that intentionally add mercury and recommend actions to achieve further reductions in mercury use. The comment deadline is set at December 26, 2017.