Understanding the Costs Associated with Eliminating Exemptions for 

Articles in SNURs

November 20, 2014

Economic and Policy Analysis Branch

Chemistry, Economics, and Sustainable Strategies Division

Office of Pollution Prevention and Toxics

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460
Notice

This document was prepared to provide economic information for the rulemaking process. Due to the 

nature of the information available to EPA, the document contains various assumptions that may not 

reflect the regulatory determinations that an individual firm or organization would make were it to apply 

the rule's requirements to its specific circumstances. This is not an official guidance document and should 

not be relied upon to determine applicable regulatory requirements. Mention of the names of specific 

companies, organizations, entities, goods, or services does not constitute an endorsement by EPA.
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Table of Contents

1 Introduction...........................................................................................................................................1

1.1 Importers.......................................................................................................................................1

1.2 Processors .....................................................................................................................................2

2 Regulatory Background ........................................................................................................................2

2.1 Selected Foreign Regulations........................................................................................................2

2.1.1 REACH - European Union ...................................................................................................2

2.1.2 REACH-like Regulations in Other Countries.......................................................................3

2.1.3 RoHS - European Union .......................................................................................................4

2.1.4 RoHS-like Regulations in Other Countries...........................................................................4

2.2 Selected Relevant U.S. Regulations (Federal and State) ..............................................................5

2.2.1 CPSIA ...................................................................................................................................5

2.2.2 California - Proposition 65....................................................................................................5

2.2.3 Washington - Children’s Safe Product Act...........................................................................5

2.2.4 Maine - An Act to Protect Children's Health and the Environment from Toxic Chemicals 

in Toys and Children's Products ...........................................................................................................6

2.2.5 Possible Future State Regulations.........................................................................................6

3 Regulated Entities.................................................................................................................................6

4 Identifying Substances Subject to a SNUR in Articles.........................................................................7

4.1 Typical Components of Process (Importers).................................................................................8

4.2 Compliance Assurance for Article Processors............................................................................10

4.3 Example Data Collection Tools and Methods ............................................................................10

4.3.1 American Apparel & Footwear Association (AAFA) Restricted Substances List .............10

4.3.2 Joint Industry Guide (JIG) ..................................................................................................11

4.3.3 Global Data Synchronization Network (GDSN).................................................................11

4.3.4 International Material Data System (IMDS).......................................................................12

4.3.5 BomCheck - Substances Declarations Database.................................................................12

4.3.6 Bluesign® Technologies AG ...............................................................................................12

4.3.7 Green Seal...........................................................................................................................12

4.4 Other Resources..........................................................................................................................13

4.4.1 Trade Association Guidance: The Apparel and Footwear International RSL Management 

(AFIRM) Working Group Supplier RSL Toolkit ...............................................................................13

4.4.2 Consulting Firm: Intertek....................................................................................................13

4.4.3 Joint Article Management Promotion Consortium (JAMP) ...............................................14

5 Costs (Importers) ................................................................................................................................14

5.1 Characteristics of Importers Affecting Cost ...............................................................................15
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5.1.1 Level of Baseline Compliance with Other Chemical Restriction Requirements................15

5.1.2 Supply Chain Complexity...................................................................................................16

5.1.3 Size of Company.................................................................................................................16

5.2 Unit Burden and Cost..................................................................................................................16

5.2.1 Understand applicable requirements (rule familiarization).................................................17

5.2.2 Identify the type of imported articles that potentially contain the chemical substances 

subject to a SNUR...............................................................................................................................17

5.2.3 Identify all suppliers involved.............................................................................................18

5.2.4 Collect data from suppliers.................................................................................................19

5.2.5 Chemical testing..................................................................................................................21

5.2.6 Recordkeeping ....................................................................................................................22

5.3 Costs for Importer Company Scenarios......................................................................................22

5.4 Summary.....................................................................................................................................25

6 Costs (Processors)...............................................................................................................................26

7 Limitations of Analysis.......................................................................................................................26

8 References...........................................................................................................................................28
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Table of Figures

Table 1: Factors Affecting the Ease of Obtaining Information on Substances...........................................15

Table 2: Loaded Industry Wage Rates, December 2012.............................................................................17

Table 3. Costs associated with a large, complex-supply chain importer that is subject to other chemical 

restriction regulations..................................................................................................................................22

Table 4. Costs associated with a large, complex-supply chain importer that is not subject to other 

chemical restriction regulations..................................................................................................................23

Table 5. Costs associated with a small, simple-supply chain importer that is subject to other chemical 

restriction regulations..................................................................................................................................24

Table 6. Costs associated with a small, simple-supply chain importer that is not subject to other chemical 

restriction regulations..................................................................................................................................24

Table 7. Range of costs associated with an importer’s identification of chemicals subject to SNURs in 

articles.........................................................................................................................................................26
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Contributors

Analytical and draft preparation support was provided by Abt Associates Inc. under EPA Contract No. 

EP-W-08-010.
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1 Introduction

Under the Toxic Substances Control Act (TSCA), there are a variety of methods available to the U.S.

EPA to gather information and limit the use of toxic chemicals. One such method is the promulgation of

Significant New Use Rules (SNURs) at 40 CFR part 721. A SNUR requires that manufacturers (including 

importers) and processors of the subject substances notify EPA at least 90 days before beginning any 

activity that EPA has designated as a “significant new use.” In general, the use designations are potential 

new uses that could result in new or increased exposures to, or releases of, the substance. The notification 

required by SNURs, known as a Significant New Use Notification (SNUN), allows EPA the opportunity 

to review and, if necessary, prevent or limit potentially adverse exposure to, or effects from, the new use 

of the substance.

In most cases, SNURs have applied to the manufacture or processing of chemical substances but have,

under 40 CFR § 721.45(f), exempted importers and processors of articles containing the chemical 

substance. Although TSCA does not specifically define “article,” the Act does refer specifically to articles 

in several provisions and provides EPA the authority to regulate chemical substances contained in 

articles. “Article” is defined in several regulations promulgated under TSCA’s authority, including 40 

CFR §§ 704.3, 710.3(d), and 720.3(c). Given the increasing evidence that toxic substances are released 

from articles during use and at the end of their useful life (Massey et al., 2008), a number of recent 

proposed SNURs, such as those for benzidine-based chemicals, polybrominated diphenyl ethers (PBDEs), 

hexabromocyclododecane (HBCD), and perfluorinated compounds (PFCs) and other final SNURs related 

to mercury and erionite fiber, have included provisions to eliminate the exemption for persons that import 

or process the chemical substances as part of articles.

With the exemption at 40 CFR § 721.45(f) made inapplicable, SNUN submission requirements are also 

triggered for persons that import or process the chemical substance as part of an article. The term “article”

is defined by EPA in the context of requirements under TSCA for the reporting of new chemical 

substances by manufacturers at 40 CFR § 720. 3(c): “Article means a manufactured item (1) which is 

formed to a specific shape or design during manufacture, (2) which has end use function(s) dependent in 

whole or in part upon its shape or design during end use, and (3) which has either no change of chemical 

composition during its end use or only those changes of composition which have no commercial purpose 

separate from that of the article and that may occur as described in § 720.36(g)(5), except that fluids and 

particles are not considered articles regardless of shape or design.” (SNURs are codified at 40 CFR part 

721, which does not include its own specific definition for “article.”) Articles can range from simple 

single-component products, such as fabric, to highly complex multi-component products such as an 

automobile. 

The costs of submitting a SNUN is addressed in the economic analyses for the individual rules, and EPA 

does not believe these costs will vary between manufacturers or processors of these chemical substances, 

as part of articles or otherwise. Importers of articles retain broad latitude to determine what, if any, 

inquiry is necessary to determine whether their future imports may contain a subject chemical substance.

This paper explores some of the compliance assurance measures these entities may employ. The 

responsibilities of processors of articles under SNUR requirements are also discussed in this paper, along 

with the likely compliance assurance measures that correspond with their limited level of liability.

1.1 Importers

Under TSCA, the definition of “manufacture” means to “import..., produce or manufacture.” Importers 

have varying levels of knowledge about the chemical content of the articles they import, yet based on this 

definition, they are responsible parties under the regulation. In order to understand and monitor their 

liability, companies might undertake a range of activities to ensure that the articles they import do not 

violate existing regulations. This paper identifies some of the resources and tools that are available to 

importers in developing and implementing their procedure to identify any chemicals subject to SNURs in 

their imported articles. The paper further describes the range of activities that businesses are likely to 
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undertake based on various characteristics including their experience with similar requirements for 

chemicals regulated under other authorities, the complexity of their supply chain, and the size of the 

company. Potential cost ranges are then estimated for importing companies based on these characteristics, 

to the extent possible. 

1.2 Processors

The term “process” is defined by TSCA § 3(10) as, “the preparation of a chemical substance or mixture, 

after its manufacture, for distribution in commerce -- (A) in the same form or physical state as, or in a 

different form or physical state from, that in which it was received by the person so preparing such 

substance or mixture, or (B) as part of an article containing the chemical substance or mixture.” There are 

a number of ways in which a company may become a processor of a chemical substance as part of an 

article. For example, a processor of a chemical substance in an article might be someone who receives an 

article and assembles it into another product for a specific use. SNUR reporting requirements for persons 

who intend to manufacture or process a subject chemical substance are described in § 40 CFR 721.5;

however, the reporting requirements for processors do not apply in some circumstances. As described in § 

40 CFR 721.5(c), a processor is not required to submit a SNUN if he can document that (1) he does not 

know the specific chemical identity of the chemical substance being processed; and (2) that he is 

processing the chemical substance without knowledge that the substance is subject to a SNUR. This paper 

focuses on the standard business practices that EPA believes a processor would already undertake that 

may document what is known about the chemicals being processed as part of articles.

2 Regulatory Background

2.1 Selected Foreign Regulations 

A number of nations worldwide place restrictions on the manufacture and use of hazardous chemicals. 

This section highlights a selection of key regulations imposed by other nations that require the 

identification of hazardous chemicals. To the extent that importers and processors of articles who are 

subject to SNURs are already subject to any of these regulations, for example because of business they 

conduct in other countries, they may have already instituted policies and procedures that would mitigate 

the cost of evaluating whether regulated chemicals are a part of articles they manage.

2.1.1 REACH - European Union

The European Union’s (EU) legislation addressing the safe use of chemicals, Regulation (EC) No 

1907/2006, known as Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH),

came into effect in 2007. It applies to all chemicals imported or produced in the EU. Manufacturers and 

importers are required to collect information on the properties of their chemicals and to submit the 

information to a central database administered by the European Chemical Agency (ECHA) in Helsinki, 

Finland (European Commission Directorate-General for the Environment (EC DG Environment), 2012a).

Under REACH, an article is “an object which during production is given a special shape, surface or 

design which determines its function to a greater degree than its chemical composition” (ECHA, 2011a).

Article producers, importers, and suppliers are subject to various registration, notification, and 

communication requirements. Generally, article producers and importers must register any substances 

intended to be released from articles if the amount present in an article totals more than one tonne per 

year and the substance is not already registered for that use. Article producers and importers must also 

provide notification about any “substances of very high concern” in articles if the amount present in an 

article totals more than one tonne per year and when the concentration of the substance in the article is 

more than 0.1 percent. Article suppliers are subject to communication of information requirements for all 

articles containing substances of very high concern, if the concentration of the substance in the article is 

more than 0.1 percent, regardless of the total amount (ECHA, 2011b).
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2.1.2 REACH-like Regulations in Other Countries

A number of other nations have adopted legislation similar to or based on the European Union’s REACH. 

For example, China’s regulation, Provisions on the Environmental Administration of New Chemical 

Substances in China came into effect in 2010 and applies mainly to chemicals and mixtures of chemicals. 

It places obligations on manufacturers of substances in China and importers of substances into China. It 

includes requirements for new chemicals that are released from articles during normal use, consistent with 

EU REACH’s requirement that intentionally released chemicals (in quantities greater than one tonne) 

must be registered (Electronics Weekly Blogs, 2010).

Additional nations continue to develop and implement regulations. For example, South Korea’s 

proposed Act on Registration and Evaluation of Chemicals (“K-REACH”) has been submitted to its 

National Assembly and is expected to come into force in 2015. Under the Act, the manufacturers or 

importers of new chemicals and priority evaluation chemicals must submit registration prior to 

manufacture and import (He, 2012).

Other countries are also requiring stricter oversight of their imports. New Zealand’s law associated with 

the management of hazardous substances is the Hazardous Substances and New Organisms Act 1996 

(HSNO Act). Under the HSNO Act, no hazardous substances can be imported or manufactured except in 

accordance with the Act or with an approval issued by the NZ Environmental Protection Authority (NZ 

EPA) under the Act. The Act applies to items falling under its definition for ‘substance,’ and delegates the 

authority to NZ EPA to develop regulations under the Act to define what is considered a “hazardous 

substance.” The initial responsibility for determining what substances are classified as hazardous 

substances under the HSNO Act rests with the importer or manufacturer of the substance. When a 

company applies to the NZ EPA to import or manufacture a hazardous substance, a classification of each 

hazardous property of the substance is determined. These hazard classifications trigger a set of regulatory 

controls developed for the level of hazard. The HSNO generally does not apply to articles, except those 

with explosive properties: manufactured articles with explosive properties (such as flares or detonators) 

are considered substances under the HSNO Act. Manufactured articles, even if they contain or incorporate 

hazardous substances with properties other than explosiveness, are not considered to be substances (NZ 

EPA, 2012). NZ EPA provides guidance to assist in determining whether an item is a manufactured

article. An article must meet all of these criteria: (1) the item was deliberately formed to a specific shape 

or design during manufacture, (2) the item has an end use function wholly or partly dependent on its 

shape or design, (3) the item undergoes no change of chemical composition during end use, except as an 

intrinsic part of that end use, and (4) the item is not a particle or fluid (NZ EPA, 2011). Although articles 

(other than explosives) would not be subject to the HSNO Act’s Controls for hazardous substances, 

articles containing a hazardous substance can be regulated under “group standards” set according to Part 

6A of the HSNO Act. A group standard provides requirements for a set of hazardous substances that have 

a similar nature, are of a similar type, or have similar circumstances of use, so that the risks of the 

grouped hazardous substances can be effectively managed by one set of conditions (NZ Parliamentary 

Counsel Office, 2012). 

Malaysia’s Environmentally Hazardous Substances Notification and Registration Scheme includes a 

notification requirement for hazardous substances manufactured in or imported to Malaysia (Malaysia 

Department of Environment, Hazardous Substances Division, 2012a). The requirements apply to 

manufacturers and importers of environmentally hazardous substances (EHS) and importers of chemical 

mixtures or finished products (e.g., articles) that contain EHS as their constituents (Malaysia Department 

of Environment, Hazardous Substances Division, 2012b).

Norway’s proposed Prohibition on Certain Hazardous Substances in Consumer Products (PoHS) would 

ban four hazardous substances (lead, pentachlorophenol (PCP), perfluorooctyl acid (PFOA), and mediumchained chlorinated paraffins (MCCP)) in nearly all consumer products above certain concentration limits 
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(Bureau Veritas Group, 2012). It applies to both imported products as well as products produced in 

Norway (Norwegian Pollution Control Authority, 2010). The ban was scheduled to take effect in 2012.

2.1.3 RoHS - European Union

The European Union’s legislation Restriction of Hazardous Substances Directive (RoHS) took effect in 

2006 and limits the use of certain hazardous substances in specific types of articles: electrical and 

electronic equipment (EC DG Environment, 2012b). RoHS restricts the use of the following six 

substances: lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (Cr6+), polybrominated 

biphenyls (PBB), and polybrominated diphenyl ether (PBDE) in several categories of electrical and 

electronic equipment including household appliances, information technology (IT), and consumer 

equipment. RoHS allows a maximum concentration of 0.1 percent by weight in homogenous materials for 

lead, mercury, hexavalent chromium, PBB, and PDBE and 0.01 percent by weight in homogenous 

materials for cadmium. “Homogeneous material” means a material that cannot be mechanically disjointed 

into different materials.

In 2011, a revised version of RoHS (RoHS2) took effect which provides for a gradual extension of the 

requirements to all electrical and electronic equipment (EEE) (European Parliament, 2011). European 

member countries were required to adopt RoHS2 by transposing the regulation into their national laws by 

January 2, 2013 (EC DG Environment, 2012c).

RoHS places specific requirements on importers. Under RoHS2, importers may sell only compliant EEE 

on the European Union market. Before placing EEE on the market, an importer must ensure that the 

appropriate conformity assessment procedure has been carried out by the manufacturer, and ensure that 

the manufacturer has drawn up the technical documentation, that the EEE bears the required marking and 

is accompanied by the required documents (European Parliament, 2011).

2.1.4 RoHS-like Regulations in Other Countries

Several nations have adopted regulations similar to or based on the EU’s RoHS. For example, the 

People’s Republic of China enacted the Administrative Measure on the Control of Pollution Caused by 

Electronic Information Products, or “China RoHS,” as it is commonly called, in 2006. China’s regulation 

focuses on the same six substances as the EU RoHS and requirements are similar. However, China’s

regulation applies to all “electronic information products” which are listed on the Ministry of Information 

Industry of the People’s Republic of China (MII) website (IPC, 2009). An unofficial English translation 

of this list was produced by American Electronics Association (2006). 

South Korea’s Act for Recycling of Electrical and Electronic Equipment and Automobiles, known as 

“Korea RoHS,” came into effect in 2008. Korea RoHS applies to the following EEE: televisions, 

refrigerators, mobile telephone terminals (including batteries and chargers), washers (limited to those for 

household use only), personal computers (including monitors and keyboards), audio equipment, airconditioners, printers (including ink cartridges and toner cartridges), copiers (including ink cartridges and 

toner cartridges), fax machines (including ink cartridges and toner cartridges); and the following types of 

vehicles: passenger cars, vans, and trucks less than 3.5 tons. It applies to the same six substances as the 

EU RoHS, with the same concentration limits in homogeneous materials, but the PBB and PBDE 

restrictions do not apply to vehicles (ERA Technology Ltd., 2008).

Japan’s Law for Promotion of Effective Utilization of Resources incorporates the Japanese Industrial 

Standard JIS C 0950, titled The Marking for Presence of the Specific Chemical Substances for Electrical 

and Electronic Equipment (MOSS). The law applies to the manufacturers and importers of the following 

products: personal computers, unit-type air conditioners, television sets, refrigerators, washing machines, 

clothes dryers, microwaves. It applies to the same six substances as the EU RoHS, and requires that the 

products listed above be marked to indicate the presence of the substances (Japan Electronics and 

Information Technology Industries, 2008). 
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2.2 Selected Relevant U.S. Regulations (Federal and State)

U.S. importing and processing companies may already be familiar with the process of determining 

whether they are importing or processing particular restricted chemical substances as part of articles, if 

they are subject to U.S. regulations such as the following. 

2.2.1 CPSIA

The Consumer Product Safety Improvement Act (CPSIA) of 2008 authorized regulations and testing 

requirements for children’s products and some non-children’s products. The Act limits the amount of lead 

allowed in surface coatings or paint on any consumer product designed or intended primarily for children 

12 years of age or younger to 90 ppm and reduces the amount of total lead content in children’s products 

to 100 ppm, unless not technically feasible. The Act also makes it unlawful for any person to manufacture 

for sale, distribute in commerce, or import any children’s toy or childcare article that contains the 

phthalates di-2-ethylhexyl phthalate (DEHP), dibutyl phthalate (DBP), or benzylbutylphthalate (BBP) at 

levels higher than 0.1 percent (U.S. Consumer Product Safety Commission (CPSC), 2008a). An interim 

ban has also been placed on the phthalates diisononyl phthalate (DINP), diisodecyl phthalate (DIDP), and 

di-n-octyl phthalate (DnOP) at levels higher than 0.1 percent in toys that can be placed in a child’s mouth 

and in child care articles (U.S. CPSC, 2008b). More information on total lead content in children’s 

products under CPSIA can be found on the U.S CPSC’s Total Lead Content website (U.S. CPSC, 2008c). 

More information on phthalates regulation under CPSIA can also be found on the U.S. CPSC’s Phthalates

website (U.S. CPSC, 2008b).

2.2.2 California - Proposition 65

California’s Proposition 65 (Prop 65) restricts the use of listed toxic chemicals known to cause cancer or 

birth defects or other reproductive harm in products sold and used in California. California Prop 65, 

known as the Safe Drinking Water and Toxic Enforcement Act, was enacted in California in 1986. The 

Act affects all products sold or distributed in California, including textiles, hard goods, toys, juvenile 

products, and electrical/electronic items. Prop 65 requires businesses to provide residents with 

notifications of significant amounts of chemicals in their products, in their homes or workplaces, or that 

are released into the environment. By providing this information, Prop 65 enables residents to make 

informed decisions about protecting themselves from exposure to these chemicals. This Act requires that 

anyone in the course of doing business who exposes an individual to a chemical “known to the State” to 

cause cancer or reproductive toxicity must first give a “clear and reasonable” warning. Currently, over 

881 chemicals are listed by the State of California as known carcinogens or reproductive toxins

(California Office of Environmental Health Hazard Assessment, 2010). The current Prop 65 list of 

chemicals is located at http://oehha.ca.gov/prop65/prop65_list/newlist.html (California Office of 

Environmental Health Hazard Assessment, 2013).

2.2.3 Washington - Children’s Safe Product Act

Under the Children’s Safe Product Act, the State of Washington makes manufacturers of children’s 

products responsible for reporting the presence of chemicals of high concern to children. The first part of 

the Act limited the amount of lead, cadmium and phthalates allowed in children’s products sold in 

Washington after July 1, 2009. These standards were substantially preempted when the U.S. Congress 

passed the Consumer Product Safety Improvement Act (CPSIA) in July, 2008. The second part of the law 

mandates two state departments in Washington to develop a list of toxic chemicals that have either been 

found in children’s products or have been documented to be present in human tissue (blood, breast milk, 

etc.). This list is known as the “Reporting List of Chemicals of High Concern to Children” and can be 

found on the Washington State Department of Ecology’s website (n.d.-a). Manufacturers must report on 

the content of these listed chemicals in their children’s products. The Act broadly defines “manufacturer” 

to include the producer, importer, and domestic distributor of the product. It establishes a hierarchy for 
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determining which entities meet the statutory definition of “manufacturer” that the department will hold 

primarily responsible for ensuring that reporting requirements are satisfied with respect to any children’s 

product (Washington State Department of Ecology, n.d.-b). 

2.2.4 Maine - An Act to Protect Children's Health and the Environment from Toxic Chemicals in 

Toys and Children's Products

Maine’s Act to Protect Children’s Heath and the Environment from Toxic Chemicals in Toys and 

Children’s Products, as enacted in 2008, calls for the identification of chemicals of high concern as 

“priority chemicals” based on exposure of a child or fetus. Manufacturers or distributors of children’s 

products for sale in Maine must provide notification of any product containing a priority chemical (Maine 

Legislature, 2008). A list of chemicals found on Maine’s List of Chemicals of High Concern is available 

online (Maine Department of Environmental Protection, 2012). Implementation of the rule is intended to 

be done in collaboration with Washington State’s Department of Ecology, consistent with their Children’s 

Safe Product Act program (Maine Department of Environmental Protection, 2011).

2.2.5 Possible Future State Regulations

According to an analysis by Safer States (a national coalition of state-based environmental health 

organizations), during 2013 several states introduced bills to reduce exposure to harmful chemicals (Safer 

States, 2013). As of June 2013, at least 28 states are considering policies to address concerns over toxic 

chemicals in consumer products. The bills cover a broad range of topics, including bans in consumer 

products and disclosure requirements. Some categories of chemicals being considered are:

1) Toxic Flame Retardants: At least 15 state legislatures are considering policies to phase out the 

use of toxic flame retardants, including Tris (1,3-dichloro-2-propyl) phosphate (chlorinated Tris)

in consumer products such as children’s products, home furniture, and building insulation. 

Chlorinated Tris is found in products made of foam and is considered a carcinogen under 

California’s Proposition 65 (California Office of Environmental Health Hazard Assessment, 

2013). States that are considering restrictions on flame retardants include California, Connecticut, 

Delaware, Illinois, Maine, Massachusetts, Maryland, Missouri, New Jersey, Nevada, North 

Carolina, New York, Oregon, Vermont, and Washington.

2) Bisphenol A: At least 16 states are considering policy to restrict or label the use of the endocrinedisrupting chemical Bisphenol A (BPA) in items such as baby food jars, infant formula and other, 

food/beverage packaging, children’s products, and plastic containers. States that have introduced 

such bills include Arizona, Connecticut, Hawaii, Kentucky, Massachusetts, Maine, Minnesota, 

Nevada, New Jersey, New York, North Carolina, Pennsylvania, South Dakota, Tennessee, Texas, 

and West Virginia.

3) Chemicals Harmful to Children: At least 10 states, including Alaska, Connecticut, Delaware, 

Florida, Maine, Massachusetts, Minnesota, New York, Oregon, and Vermont, will consider 

additional bills to identify chemicals of concern for children’s health and/or require makers of 

consumer products to disclose their use of the chemicals. Many of these bills include provisions 

to encourage manufacturers to identify and use safer alternatives in their products.

Links to the bills introduced in each state can be found on Safer States’ website (Safer States, 2013).

3 Regulated Entities

Without the exemption at 40 CFR 721.45(f) applicability to importers and processors of the subject 

chemical substances as part of articles to the SNUN provisions is expanded. Once such a SNUR becomes 

effective, importers and processors of articles may take steps to ensure that they do not import or process 

the regulated chemicals as part of an article in a manner that would constitute a significant new use as 

described by the SNUR. Given the scope of the term “article” (under 40 CFR part 720, an item formed to 

a specific shape or design during manufacture, which has end use function(s) dependent in whole or in 

part upon its shape or design during end use), the applicability of SNURs potentially increases 
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significantly. A report prepared for the European Commission/ Directorate-General Enterprise on costs of 

regulating chemicals as part of articles under REACH estimates that there are between 500,000 and 5 

million imported article types that are subject to REACH, falling under approximately 5,300 product 

categories (Risk and Policy Analysts Limited (RPA), 2003).

An estimation of the specific number of product sectors is challenging, because applicability of each 

SNUR to a type of industry would depend on the specific chemicals covered by the SNUR, and their 

known uses.

The Nordic Council of Ministers 2010 report REACH Trigger for Information on Substances of Very 

High Concern (SVHC) provides an understanding of the types of product groups known to be of concern 

regarding content of toxic chemicals (which can provide some insight into product types that may be the 

subject of a SNUR). In order to present a broad picture of the realities in different product sectors, case

studies were selected by the report authors. The selection was performed by identifying product groups 

containing articles meeting the following criteria: 

 Known presence of SVHC in the article 

 Variety and complexity of the articles 

 Relevant share of production within EU and of import into the EU-market 

 Different possible exposure pathways from the SVHC contained (human health, environment) 

The initial case study pre-selection led to the following product groups: 

1) Cars and parts of cars, e.g. seats, tires

2) Electronics 

3) Computers 

4) White goods 

5) Furniture 

6) Home trainer [home exercise equipment]

7) Roofing felt 

8) Shoes 

9) Textiles 

10) Tools 

11) Toys 

12) Windows 

Additionally, the United Nations Environment Programme’s (UNEP’s) A Synthesis of Findings Under the 

UNEP/IOMC Project on Information on Chemicals in Products identified product sectors of “highest 

priority” for focus related to stakeholder information needs on chemicals in products (UNEP/DTIE 

Chemicals Branch, 2011). Product sectors of highest priority were: 1) children's products/toys, 2) 

electronics, 3) clothing, and 4) construction materials.

The applicability of a SNUR to importers or processors within a particular industry is dependent on the 

specific chemical substance(s) covered by the SNUR, and can include a wide variety of sectors with a 

large number of entities. For any SNUR without the article exemption, the subject article importers or 

processors of chemicals in articles could fall into one or many industry sectors; a number of diverse 

article importers or processors could potentially be affected. To develop a robust estimate of the number 

of entities given readily available information would not likely be possible given the uncertainties 

involved.

4 Identifying Substances Subject to a SNUR in Articles

Under a SNUR with no exemption for persons that import or process the chemical substance(s) as part of 

articles, importers may determine whether the articles they import are likely to contain the regulated 

chemical substance, and if so, comply with the notification requirements of the SNUR (notify EPA at 
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least 90 days before commencing the import of any articles containing chemicals subject to the rule). 

Processors may be unlikely to undertake additional activities specifically to identify subject chemical 

substances in the articles they process given the standard applied to processors in §721.5(c), described in 

Section 1.2. Rather, processors would demonstrate compliance through their existing documentation, as 

described in Section 4.2. To the extent that processors desire extra certainty that the articles they process 

are not subject to a SNUR, they may undertake the steps in the process outlined below for importers.

RPA (2003) identified general methods for obtaining information on substances in articles: literature 

review; written questionnaires/telephone contact; and chemical analysis. Thus, making the determination

of whether an article contains a substance subject to a SNUR may involve using existing information 

about the product and/or chemicals; gathering information from suppliers; and/or testing samples of the 

article itself. The industry consensus standard ASTM F2577 Standard Guide for Assessment of Materials 

and Products for Declarable Substances provides some guidance in developing a process for the 

determination.

Given the existing regulatory limitations on certain chemicals both internationally and within the United 

States (as described in Section 2), regulated industries have begun to develop industry-wide processes and 

other resources to support such a determination. Massey et al. (2008) describe information systems that 

have been developed on a voluntary basis. These systems for managing the chemicals in their supply 

chain fall into four categories: 

1) Restricted and preferred substance lists: Suppliers sign agreements certifying that specified 

products do not contain restricted substances. (e.g., American Apparel & Footwear Association 

(AAFA) Restricted Substances List)

2) Surveys/questionnaires: Importers require suppliers to complete forms providing information on 

chemicals contained in components (e.g., Joint Industry Guide for Material Composition 

Declaration for Electronics Products (JIG)); 

3) Databases: Importers direct suppliers to report the use of specific (or all) chemicals used in their 

products to a database (e.g., Global Data Synchronization Network (GDSN), International 

Material Data System (IMDS), BOMcheck); 

4) Third-party certifications/labeling (e.g, Bluesign® standard, Green Seal).

Based on the ASTM industry standard, and the strategies listed above, Section 4.1 provides a generalized 

list of the activities that a company may take to identify a substance subject to a SNUR in articles. Section 

4.3 describes in more detail some of the available tools and methods for companies to collect data from 

their suppliers. Section 4.4 provides examples of organizations that are further providing services or 

guidance to assist importers in managing the chemicals in their supply chain.

4.1 Typical Components of Process (Importers)

The elimination of the exemption at 40 CFR 721.45(f) for importers and processors of chemicals as part 

of articles would require notification to EPA before the importation of articles containing the regulated 

chemical substance(s) for a significant new use. Because the rule would not prescribe the steps that an 

importer must take to identify a chemical subject to a SNUR in articles, there are a variety of specific 

actions that a company could take to identify specific substances in its articles. EPA expects that in all 

likelihood, importers would take actions that are commensurate with the perceived likelihood that the 

regulated chemical is part of the article they intend to import, and the resources it has available.

ASTM’s Standard Guide for Assessment of Materials and Products for Declarable Substances (“ASTM 

F2577”) provides guidance for the decision process to assess materials and products for declarable 

substances. ASTM International, formerly known as the American Society for Testing and Materials 

(ASTM), is recognized worldwide for the development of international voluntary consensus standards. 

Developed in response to regulations restricting materials used in finished goods, such as REACH and 
Internal Deliberative-- Do Not Cite or Distribute 9

RoHS, ASTM F2577 seeks to provide a consistent method to comply with these and other similar 

regulations (ASTM International, 2012).

ASTM F2577 provides a general description of the process of assessing materials and/or products for the 

content of declarable (or restricted) substances. It relies on two means for this assessment: both a priori

and a posteriori knowledge. Therefore, determinations can be made based on information gleaned 

through logical deduction and scientific principles (a priori knowledge), as well as on observation, 

experience and known facts (a posteriori knowledge) including laboratory tests to verify or generate 

information on the concentration of a chemical substance.

The following list of activities that an importer might perform to identify specific chemicals in imported 

articles was developed based in part on ASTM F2577 and on example processes described in industry 

guidance, such as AFIRM (2011). This list is intended to capture the general types of activities

performed. Whether or not an individual importing company undertakes each specific listed activity, and 

the extent to which each is performed, likely depends on a number of factors that are outlined in Section 

5.

1) Understand applicable requirements. The importer would read and understand the SNUR, 

within the context of the company’s products. As noted in ASTM F2577-06, “The first step in 

any assessment is to determine what is covered by requirements, or the scope of the 

requirements.” Frequency: this would be a one-time activity for the importing company.

2) Identify the types of imported articles that potentially contain the chemical(s) subject to a 

SNUR. A list of the kinds of articles that the company imports that have the potential to contain 

the chemical(s) subject to a SNUR can be developed based on an understanding of the uses of the 

subject substance; broad use categories for SNUR-regulated chemicals are often known, e.g., 

used in textile dyes, laundry detergents, consumer electronics, etc. Imported articles that fall into 

highly regulated categories, such as building products, furniture glues, textiles, etc., are 

candidates for particular scrutiny. ASTM F2577-06 says to “apply a priori knowledge [based 

upon scientific principles and logical deduction] of the material and its manufacture to assess the 

probability whether each [regulated] substance may be present.” The level of effort called for

here may depend on the complexity of the imported article itself; an airplane, for example, has 

many components to consider.

Frequency: an initial review of the company’s imports would be a one-time activity; however, a 

company may do a similar review on each potential new product imported to determine whether 

it likely contains restricted chemical substances.

3) Identify all suppliers involved. Importers may identify the suppliers from whom the articles 

identified in the previous step are imported, and as necessary, make them aware of the SNUR on 

the regulated chemical.

Frequency: an initial identification of suppliers would be a one-time activity; however, an 

importer may assess each new supplier.

4) Collect data from suppliers. Importers may obtain verification from suppliers that the regulated 

chemical substance is or is not found in the article. This may be accomplished through any of the 

strategies described in the introduction to Section 4 above – for example, agreements with 

suppliers, declarations through databases or surveys, or by using a third-party certification 

system.

Frequency: initial data collection from suppliers would be a one-time activity, and any additional 

data collection a company undertakes as new products are considered for import and suppliers 

change would add to the cost. A company may also make periodic confirmations with suppliers 

reporting any changes in the article’s content or manufacturing process. 
Internal Deliberative-- Do Not Cite or Distribute 10

5) Chemical testing. Importers may assess imported articles for chemical content. This could 

involve requiring suppliers to provide certificates of analysis/laboratory reports for a lot or batch 

of the material produced. Importers could perform their own laboratory testing of articles (or 

components of articles) to determine if they contain a substance subject to a SNUR. This could be 

done, as suggested in ASTM F2577-06, as “good practice to periodically confirm material data.” 

Testing may also be done where there is no other information available.

Frequency: as needed. The amount of testing performed would depend on the number of articles 

and suppliers, and would vary as new products are considered for import and suppliers change.

6) Recordkeeping. It is expected that the importer may keep records confirming the activities 

completed. This activity is recommended by ASTM F2577-06, in the following statement, 

“Document the assessment process for each material or product. Documentation in the form of 

data and illustration of the assessment process is necessary to back up statements of compliance 

for materials and products.” Frequency: as necessary.

4.2 Compliance Assurance for Article Processors

There are a number of ways in which a company can be a processor of chemical substances in an article. 

A company that assembles a product out of various supplied parts (articles) could be a processor of the 

chemical components of those parts. For example, a processor could be a company making blankets out 

of fabric, or a company manufacturing furniture out of treated wood. Under § 40 CFR 721.5(a)(2), 

manufacturers or processors of subject chemical substances who distribute the substance in commerce 

must notify the recipient, in writing, of the applicability of SNUR requirements, or document that the 

recipient has such knowledge or will not undertake any significant new use described in the rule. 

Therefore, as the recipient of any subject chemical substance, the processor of a subject chemical as part 

of an article should receive written notification from the supplier, and would presumably keep this 

documentation as part of their standard business practice along with other documentation such as Material 

Safety Data Sheets, shipping or labeling documents, etc. that may provide information on the chemicals in 

the articles they process. Review of this documentation and flagging any chemicals subject to a SNUR or 

any other requirement are believed to be standard business practice. If a processor desires still greater

certainty that it is in compliance with a SNUR (above and beyond being able to document, after-the-fact, 

that any processing of the subject substance was without knowledge), it may undertake further steps 

similar to those outlined in Section 4.1 (i.e., screen the articles it processes as an importer would screen 

the articles it imports). EPA expects that in all likelihood, the extent that any of these activities would be 

performed would be commensurate with the perceived likelihood that the regulated chemical is part of the 

article that they intend to process, and the resources it has available.

4.3 Example Data Collection Tools and Methods

There is currently no single, widely accepted standard procedure to identify regulated chemicals in supply 

chains (Swedish Monitoring Board, 2002; RPA, 2003; Massey et al., 2008). However, there are a number 

of organizations that help provide information on the content of articles, organize declarations from 

suppliers, or certify suppliers based on materials or processes used. Furthermore, there are continued 

efforts by organizations, such as the Internation Council of Chemical Associations (ICCA) (through its 

Global Product Strategy), to encourage improved product stewardship with downstream customers in the 

chemical industry (Internation Council of Chemical Associations, 2013). Importers (or processors)

subject to SNURs may refer to these sources for assistance in their own strategy to identify a chemical 

subject to a SNUR in articles. Some examples are described below. The list is not all inclusive and 

resources are continually being developed.

4.3.1 American Apparel & Footwear Association (AAFA) Restricted Substances List

The American Apparel & Footwear Association (AAFA) Restricted Substances List (RSL) “is intended to 

provide apparel and footwear companies with information related to regulations and laws that restrict or 
Internal Deliberative-- Do Not Cite or Distribute 11

ban certain chemicals and substances in finished home textile, apparel, and footwear products around the 

world.” (AAFA, 2013). The RSL is a tool for the apparel and footwear industry that lists materials, 

chemicals, and substances that are restricted or banned in finished home textile, apparel, and footwear 

products because of a regulation or law; that is, it is specific to requirements for finished products, not 

substances used during the manufacturing process. It does not include California Proposition 65 

requirements for labeling. The list is reviewed and updated every six months (AAFA, 2012a). The most 

recent version was published in March, 2013 (AAFA, 2013). According to Massey et al. (2008), firms are 

using this list to develop internal materials tracking programs to ensure that specific substances (e.g., 

those that are regulated, restricted, or of interest due to corporate policies) are accounted for. These 

companies require that suppliers sign agreements certifying that specified products do not contain 

substances that are of interest to the company. In addition, some agreements specify that if testing 

identifies a restricted material, the supplier must cover all associated costs.

The AAFA RSL is intended to be used by industry in conjunction with the Apparel and Footwear 

International RSL Management (AFIRM) Group’s Supplier RSL Toolkit industry guidance that is focused 

on the elimination of restricted substances from finished products. (See section 4.4.1) of this report for 

more information on the AFIRM toolkit.) Additionally, AAFA has developed a List of Non-Regulated 

Substances Contained in AFIRM RSL Guidance (AAFA, 2012b). This list was based on the work 

done by the AFIRM group and includes chemicals that are neither regulated nor proven to be dangerous, 

but may be of note to the industry.

4.3.2 Joint Industry Guide (JIG)

The Japan Green Procurement Survey Standardization Initiative (JGPSSI) has been working on 

standardizing survey instruments for the electric and electronics sector in Japan. Such standardized survey 

instruments are used by companies in collecting information about the composition of chemical 

substances in their products. In conjunction with the Electronics Industry Alliance (EIA) and the 

European Information and Communication Technology Industry Association (EICTA), JGPSSI has 

developed the Joint Industry Guide (JIG) for Material Composition Declaration for Electronic Products. 

The JIG is a standardized survey used to communicate the composition of chemicals in electronic 

products between suppliers and customers. The survey is initiated by the customer (“requester”) with the 

supplier (“respondent”) asked to indicate where specific chemicals have been used in the components 

they supply. Since the survey form is standardized, the process of filling out the requisite information is 

simplified as suppliers and customers are not surprised by the request. The survey is a one to two page 

instrument and the chemical management system includes about 340 specific chemicals arranged into 24 

groups (Japan Green Procurement Survey Standardization Initiative, 2006).

4.3.3 Global Data Synchronization Network (GDSN)

The Global Data Synchronization Network (GDSN) is a customizable data management platform that 

enables companies to share information about their products with their trading partners. For example, 

Wal-Mart has created a new data management system contained within the GDSN that tracks materials 

present in chemical-intensive products (such as cleaning and personal care products). Wal-Mart’s system 

allows suppliers to submit detailed information about chemical ingredients to a third party, which in turn

keeps this information confidential. Suppliers may direct the third party to grant Wal-Mart access to 

selected information stored in the system (Wal-Mart, 2012).

While this system was initially designed to document the ingredients of chemical-intensive products, it 

may be adapted to manage information on the contents of any article. The system can also store 

information that may be relevant for future regulations, sustainability, or purchasing initiatives. Other 

potential advantages of the GDSN include safer shipping, handling, storage, and disposal; increased 

consistency and accuracy of data; improved regulatory compliance; and cost reductions and efficiency 

improvements (Massey et al., 2008). Many retailers and grocery chains currently use GDSN; services do 
Internal Deliberative-- Do Not Cite or Distribute 12

not seem limited to particular industry sectors. Membership fees are based on a company’s revenue, and 

are detailed in Section 5.2.4. 

4.3.4 International Material Data System (IMDS)

The European Union's End-of-Life Vehicle (ELV) Directive is intended to increase recycling of materials 

used in vehicles and to reduce pollution associated with vehicle dismantling. This directive, as well as 

other factors, has made it important for auto manufacturers to track the chemicals present in the products 

they receive from their suppliers. To this end, they have built an online system to facilitate information 

exchange with suppliers. The International Material Data System (IMDS) is an online database that 

suppliers use to provide information on substances in the parts they sell to auto manufacturers. Suppliers 

register for this database and enter information on substances present in their products. In 2006, the IMDS 

listed more than 8,000 substances. The IMDS also contains a default list of 111 substances that are likely 

to be present in a vehicle at the point of sale and must be declared (Massey et al., 2008).

This system could serve as a useful model for data management in other industries. However, an auto 

industry representative noted that data management technology has improved since the IMDS was 

designed, and a newer tool could offer enhanced efficiency and functionality (Massey et al., 2008).

4.3.5 BomCheck - Substances Declarations Database

BOMcheck provides a resource for importers and product manufacturers to gather substance declarations 

from their suppliers. The process is initiated by a product manufacturer or importer directing their 

suppliers to register the use of either specific chemicals or all chemicals in the production of hardware 

articles and electrical and electronic equipment. If the supplier also uses other (“secondary”) suppliers for 

providing components for the manufacture of components needed for the original manufacturer, they may 

direct these secondary suppliers to also register the use of these chemicals. In order to register chemicals

used in the supply chain, suppliers need to be registered with BOMcheck. A Regulatory Compliance 

Declaration (RCD) is provided by BOMcheck after a supplier has registered their use of chemicals. The 

tool for the RCD includes expert regulatory guidance on all substances which are restricted or declarable 

for hardware products by regulations in North America, Europe and Asia Pacific (ENVIRON, 2013a).

4.3.6 Bluesign® Technologies AG 

Bluesign Technologies AG is a private firm that works with suppliers within the fabrics supply chain to 

assure manufacturers and retailers that fabrics have been produced taking environmental protection and 

health and safety of workers and customers into account. Bluesign Technologies AG achieves this by 

providing tools to assist suppliers to exclude substances which are potentially hazardous to human health 

or the environment from processes at the outset through an intelligent Input Stream Management system. 

It is an independent standard that can be applied to the entire production chain and that delivers certainty 

at all levels, from raw material to final product, from chemical supplier to consumer (Bluesign 

Technologies AG, 2011). 

Based on assessments by Bluesign Technologies AG, components, production processes and technology 

used in the fabrics supply chain may fall in 3 color-coded rankings: Blue for those that have been checked 

according to five Bluesign Technologies AG standard principles – these may be used for all applications 

under the Bluesign standard; gray for those that may be used under one or more pre-conditions following 

the principles of the best available technology; and black for those not to be used in fabrics. The textile 

product is certified only if the raw materials and technologies used meet the criteria of the Bluesign 

standard in a concluding assessment at the respective production plant (Bluesign Technologies AG, 

2011).

4.3.7 Green Seal

Green Seal is a non-profit organization that develops “life cycle-based sustainability standards for 

products, services and companies and offer third-party certification for those that meet the criteria in the 
Internal Deliberative-- Do Not Cite or Distribute 13

standard” (Green Seal, 2012a). A product that has achieved Green SealTM Certification has met rigorous, 

science-based leadership standards. For example, the Green Seal Certification Checklist for soaps, 

cleansers, and shower products lists prohibited components including the following: 2-butoxyethanol; 

alkylphenol ethoxylates; butylated hydroxytoluene; ethoxylated chemicals; ethylene diaminetetra-acetic 

acid or any of its salts; formaldehyde donors; heavy metals including lead, hexavalent chromium, or 

selenium both in the elemental form or compounds; halogenated organic solvents; methyldibromo 

glutaronitrile; monoethanolamine, diethanolamine, and triethanolamine alone or in compounds; nitromusks; parabens; phthalates; and polycyclic musks (Green Seal, 2012b).

If a SNUR-regulated chemical substance is prohibited in Green Seal’s certification process, then an 

importing company may use a Green SealTM Certification to help determine that an article does not 

contain the chemical. 

4.4 Other Resources

There are a number of organizations, worldwide, that work to provide their stakeholders with guidelines 

and procedures to assist in identifying restricted chemicals. This section provides a brief description of 

examples of these types of organizations. Mention of resources is solely for illustrative purposes; it does 

not represent a recommendation or endorsement of the particular organization. 

4.4.1 Trade Association Guidance: The Apparel and Footwear International RSL Management 

(AFIRM) Working Group Supplier RSL Toolkit

The Apparel and Footwear International RSL Management (AFIRM) Working Group has developed a 

toolkit (AFIRM, 2011) for suppliers that is meant to help reduce the use of harmful substances in the 

apparel and footwear supply chain. The toolkit provides information and guidelines that enable AFIRM 

companies to create a Restricted Substances List (RSL). An RSL is a list of chemicals and other materials 

that suppliers and other members of their supply chains ban from use during the manufacturing product or 

from finished products entirely. AFIRM suppliers are responsible for educating their vendors on their 

RSL requirements.

The AFIRM Supplier Toolkit (2011) sets forth guidelines, information, and suggestions for suppliers to 

implement their own RSL programs. These implementation steps, as outlined in the toolkit, include:

1) Internal Communication: Develop and publish a company policy and design an implementation 

plan.

2) Communicate to Facilities/Suppliers: Inform members of the company’s supply chain of RSL 

requirements and provide them with basic chemical and legislation information.

3) Testing and Reporting Results: Identify and communicate the company’s needs to the testing 

laboratories that ensure that verify RSL compliance.

4) Continuous Improvement Best Practices: Track changes in legislation relevant to restricted 

substances in apparel manufacturing and adopt new, more stringent requirements.

4.4.2 Consulting Firm: Intertek

Given the rise of regulations restricting the use and distribution of harmful chemical substances both 

internationally and within the U.S., various consulting firms now specialize in providing services to 

support companies in greening their supply chains. One such firm, Intertek, helps to ensure that their 

clients’ products maintain compliance throughout the entire supply chain by providing “comprehensive 

assessment, product testing, validation, product certification, and consulting services to assist 

companies [in] successfully achiev[ing] green supply chain management” (Intertek, n.d.). Specifically

targeting compliance with EU RoHS, China RoHS, REACH, and California Proposition 65, the basic

steps that they take, as outlined on their website, include:

1) Identification of applicable requirements

2) Compliance Assurance Process implementation and certification
Internal Deliberative-- Do Not Cite or Distribute 14

3) Employee and vendor communication and training

4) Supplier data collection

5) Gap Analysis and Risk Assessment

6) Product re-engineering (if required)

7) Product screening and testing based upon GAP/Risk Assessment

8) Green claims verification/certification, product labeling, and marketing launch

Their Compliance Assurance System specifically involves an assessment of risk in the supply chain, 

training to perform risk-based product assessments, definition of high risk materials and/or components, a 

test plan for products, and how to take samples from actual products for testing.

4.4.3 Joint Article Management Promotion Consortium (JAMP)

JAMP is a cross-industry consortium that seeks to promote the “establishment and dissemination of 

effective and workable mechanisms to facilitate disclosure/transfer of information on chemicals contained 

in products across the supply chain.” The consortium was initially developed for companies in Japan, and 

over time they have extended their reach to other countries in eastern Asia. In response to REACH and 

similar regulations, JAMP recognizes that there is a need for information sharing between the upstream 

and downstream companies throughout a supply chain, and that an individual company or a single 

industry association may not be able to efficiently handle this issue on its own. JAMP is working on the 

following activities:

 Creation, verification, and dissemination of management guidelines for information on chemicals 

contained in preparations and articles

 Providing tools and operating rules to disclose the information on chemical substances. This 

includes the creation of the Article Information Sheet (AIS) and “AIS Creation Guidelines” – a 

standard document that contains characteristics of articles, similar to an MSDS

 Developing the information infrastructure to share and convey article information, based on selfdeclaration, and disseminating this system domestically and overseas (see: Joint Article 

Management Promotion-consortium, 2011).

JAMP membership is open to companies or groups who have interest in chemicals contained in products. 

Members are able to participate in and provide feedback on the activities described above. Annual 

membership fees range from about $215 to $2,000.

1

5 Costs (Importers)

Obtaining an accurate estimate of the cost of the elimination of the exemption in SNURs for imported

articles is complicated by the range of activities a company may employ to determine whether their 

imported articles contain chemical substances subject to a SNUR. As noted above, there are a number of 

methods by which a company may collect data from suppliers. RPA (2003) described factors that made 

obtaining data on substances in articles from suppliers easier or more difficult:

 

1 The annual fee varies for firms of different sizes where firms with less than 100 employees pay about $215 and 

firms with more than 1,000 employees pay about $2,000.
Internal Deliberative-- Do Not Cite or Distribute 15

Table 1: Factors Affecting the Ease of Obtaining Information on Substances

Factors Making Data-Gathering Easier Factors Making Data-Gathering Harder

The organization requesting information is a major/ 

important customer of the supplier

The requesting organization is not a key customer

The requesting organization has close or longstanding 

links with the supplier

The requesting organization switches suppliers 

frequently (e.g. in fashion items)

The supplier is a large, multinational company The supplier is a small company

The supply chain is short and simple The supply chain is long and/or complex

Products and processes remain unchanged for long 

periods

Product and process development is rapid, with 

frequent changes in substances used

There is no secrecy about product composition The substance content of products is commercially 

valuable information and/or secret for other reasons

Source: Swedish Monitoring Board (2002) as cited in RPA (2003).

For the purposes of this analysis, we assume that information is available once a method of collecting it 

has been arranged (i.e., there is no secrecy issue or unwillingness to share). It is also assumed that 

companies would only reach out to their immediate suppliers of articles at first; should that supplier not 

have information on the chemical content, a company may move higher into the supply chain to gain the 

information. Therefore, the complexity of the supply chain would be a relevant factor in the cost incurred. 

Variation on the method of data collection (and therefore cost) depends on a company’s level of baseline 

activity, the complexity of the supply chains, and the size of the company. Section 5.1 describes these 

characteristics. Section 5.2 explains how the burden and cost is estimated, according to importer 

characteristics, for each of the components of the chemical identification process that was described in 

Section 4.1. Section 5.3 presents costs for various importer company characteristic scenarios. Last, 

Section 5.4 summarizes the cost findings.

This analysis acknowledges that there may be opportunity costs associated with a firm’s decision to 

simply not import an article in order to avoid issue of determining whether the article contains the SNUR 

chemical. In addition, a firm may simply decide not to import a chemical known to be part of an article

that is designated as a significant new use. While this decision would avoid any costs of making this 

determination, as discussed below, it may entail “hidden” costs of the foregone profit of not engaging in 

the commercial activity originally planned. These impacts are acknowledged; however, they are not 

quantified, since doing so requires data on firm behavior that are not available. 

5.1 Characteristics of Importers Affecting Cost

5.1.1 Level of Baseline Compliance with Other Chemical Restriction Requirements

Section 2 of this report described existing international and U.S. regulations that restrict the use of 

chemicals in articles. As a result of these regulations, we expect some article importers to already have a 

process in place to communicate with suppliers of products and manage the chemical content of their 

articles. In particular, importers in certain business sectors or geographic locations would be more likely 

to be affected by these existing regulations.

For the purpose of this analysis, we assume article importers fall into two main groups: 

 Otherwise-regulated: Article importers to U.S. states that restrict the use or otherwise regulate 

substances in articles (e.g., California’s Proposition 65), of products that are regulated at the U.S. 

federal level (e.g., children’s toys and cribs), or that import into or deal with suppliers from 

countries that restrict or otherwise regulate the use of substances in articles (e.g., countries subject 

to REACH, RoHS, etc.) would already be in compliance with these regulations and thus, already 

incur the associated costs. Importers in certain sectors, like electronics, automotive, or textiles, 
Internal Deliberative-- Do Not Cite or Distribute 16

would be expected to fall into this category because their products are highly regulated by 

international regulations and traded worldwide.

 Not otherwise-regulated: Articles importers in this category do not have any experience with (or 

current costs associated with) regulations or restrictions on chemicals in articles or dealing with 

suppliers operating under article regulations.

“Otherwise-regulated” importers are expected to have some processes in place for managing some 

chemicals in their supply chain. With a SNUR that eliminates the article exemption, these importers are

likely to modify their processes to include managing the chemical in question. For each new SNUR 

promulgated, this would involve additional actions specific to each chemical and associated articles 

subject to the SNUR, and to the associated suppliers; marginal increases in costs are expected.

“Not otherwise-regulated” importers, on the other hand, would likely put a new process in place for 

managing the chemical subject to a SNUR in their supply chain. Note that once an inexperienced importer 

is affected by a SNUR, and puts in place a system to manage the chemicals in their supply chain, they 

would be considered otherwise-regulated importers under subsequent SNURs that also affect them.

5.1.2 Supply Chain Complexity

Costs for the elimination of the articles exemption could also vary depending on the complexity of a 

company’s supply chains. The complexity of an importer’s supply chain may depend on the nature of 

products they import (industry/sector). 

For the purpose of this analysis, we assume article importers fall into two main groups: 

 Simple: An importer with a simple supply chain imports a small number of articles or product 

lines, each involving a small number of components (within a single article) or 

products/suppliers (within a product line).

 Complex: An importer can be considered complex if it fits under any of these categories: imports 

a small number of simple articles, but each with a large number of suppliers (e.g., importers of 

toys or apparel); imports a large number of different articles (e.g., retailers like Wal-Mart and 

REI); or imports a few complex items with multiple components (e.g., importers of airplanes or 

automobiles).

As a result of the smaller number of products and companies involved, it is likely easier for importers 

with simple supply chains to identify their suppliers and work with them to identify chemicals in the 

articles they import. Importers with complex supply chains may have to identify all suppliers of their 

product, contact all of them and work with them to identify these chemicals. It is expected that this task 

can take significantly more effort than for an importer with a simple supply chain.

5.1.3 Size of Company 

Regardless of the number of articles it imports, the method of information collection may be chosen 

depending on the size of the company (e.g., number of employees) or the resources at its disposal (e.g., 

annual revenue). Larger companies may be better equipped to set up infrastructure related to chemical 

data management, such as developing their own databases or questionnaire methodology.

5.2 Unit Burden and Cost

This section presents estimates of the range of unit costs for each of the components of the process 

outlined in Section 4.1, based on importer characteristics.

Various categories of employees of the importer company will be involved in conducting the elements of 

the process. Consistent with EPA SNUR economic analyses, we define three labor categories: clerical, 

technical, and managerial. Table 2 shows the wage rates for each of these labor categories.
Internal Deliberative-- Do Not Cite or Distribute 17

Table 2: Loaded Industry Wage Rates, December 2012

Labor 

Category Data Sources Date

Wage

(2012$)

Fringe 

Benefit

(2012$)

Fringes 

as % 

wage

Overhead 

% 

wage2

Fringe + 

overhead 

factor

Loaded 

Wages1

(2012$)

(a) (b) (c) 

=(b)/(a) (d) (e)=(c)+(d)+1

(f)=(a) x 

(e)

Managerial

BLS ECEC, Private 

Manufacturing 

industries, “Mgt, 

Business, and 

Financial”3

Dec12 $43.95 $21.45 48.81% 17% 1.66 $72.87

Professional/

Technical

BLS ECEC, Private 

Manufacturing 

industries, “Professional 

and related“3

Dec12 $38.53 $19.30 50.09% 17% 1.67 $64.38

Clerical

BLS ECEC, Private 

Manufacturing 

industries, “Office and 

Administrative Support”

3

Dec12 $17.64 $8.87 50.28% 17% 1.67 $29.51

Notes:

1 Wage data are rounded to the closest pennies in this table; however, in calculations using these numbers for this report, 

unrounded values were used.

2 An overhead rate of 17% was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release 

Inventory Program (EPA, 2002).

3 Employer Costs for Employee Compensation Supplementary Tables December 2012, U.S. Bureau of Labor Statistics, March 

18, 2013 (BLS, 2013).

5.2.1 Understand applicable requirements (rule familiarization)

It is assumed that importer company staff will familiarize themselves with the requirements of the SNUR. 

This involves reading the rule, understanding the various reporting and administrative requirements, and 

determining the manner in which the reporting requirements will be met. Based on the most recent 

Information Collection Request supporting statement for SNURs, the burden for this activity is estimated 

to be 0.27 hours of managerial time, and 0.55 hours of technical time (U.S. EPA, 2012). This level of 

burden is assumed to be the same for all companies regardless of their characteristics. At the hourly wage 

rates listed in Table 2, the total cost of rule familiarization is approximately $55 per firm, per rule. This 

burden and cost is typically already included in Economic Analyses for SNURs for all firms subject to the 

rule.

 Burden and Cost Associated with Activity 1: Understand Applicable Requirements (Rule 

Familiarization):

 Approximately 0.82 hours and $55 per rule

 This cost is typically already accounted for in SNUR economic analyses.

5.2.2 Identify the type of imported articles that potentially contain the chemical substances

subject to a SNUR.

This step involves reviewing the inventory of articles imported by the company and developing a list of 

the type of articles that are likely to be subject to the SNUR. This list also could be used to determine 

whether articles the importer may decide to import in the future could contain a regulated chemical. 

Companies would likely review whether the articles (or the articles manufacturing process) fall under any 

of the use categories that are known for the regulated chemicals. Information published by EPA with a 

SNUR may describe known uses of the chemical; more thorough research may be warranted. 
Internal Deliberative-- Do Not Cite or Distribute 18

The level of effort required for this identification is assumed to depend on the number of products 

imported; importers that are considered to have a complex supply chain, as described in Section 5.1.2,

would likely have a higher burden. 

Burden is estimated based on another activity described in SNUR Economic Analyses, under the Export 

Notification costs. Section 12(b) of TSCA requires exporters to notify EPA if they export or intend to 

export a chemical subject to various TSCA sections. As part of the calculation of this cost in the context 

of a SNUR, EPA estimates the cost to compile and maintain the list of affected chemicals and mixtures. 

For this activity, respondents need to check for new SNUR regulations promulgated and any chemicals 

and mixtures exported by the company. We assume that the level of effort involved in identifying 

chemicals that are exported and creating and maintaining lists of these chemicals and mixtures is 

reasonably similar to that that an article importer might expend in identifying those articles that may 

potentially contain regulated substances as part of the article, since importers are generally aware of the 

industry sectors associated with use of their products. Therefore, we assume costs for this activity will be 

the same as those for a similar activity estimated for Section 12(b) export notification requirements.

Updating their product list is estimated to take an average of one hour of technical time, which may also 

include some proportion of legal time (U.S. EPA, 2009). For each SNUR rule promulgated, the total 

burden can vary from two hours per year up to two hours per month (24 hours per year), depending on the 

number of products exported [imported] by the company (U.S. EPA, 2009). At the hourly wage rate listed 

for technical staff in Table 2, the cost of this activity is $129 for companies with simple supply chains, 

and $1,545 for companies with complex supply chains.

 Burden and Cost Associated with Activity 2: Identify the type of imported articles that 

potentially contain the restricted substances:

 Approximately 2 hours and $129 for companies with simple supply chains

 Approximately 24 hours and $1,545 for companies with complex supply chains

 Estimates are per rule, and take into consideration average number of products 

affected. Actual costs will vary based on actual number of articles imported. 

5.2.3 Identify all suppliers involved

After the potentially affected articles are identified, the importer may identify suppliers of the articles

identified in the previous step. This involves examining the company’s existing records, and potentially 

contacting the suppliers to make them aware of the chemical restrictions and the importer’s preferred data 

collection method. Burden is assumed to vary depending on the number of suppliers.

Burden is estimated based on the cost for supplier notification associated with reporting requirements for 

the Toxics Release Inventory (TRI). Under TRI reporting requirements, facilities supplying mixtures and 

products containing listed chemical substances must notify their customers of the contents of their 

products on an annual basis. This notification can be provided as a letter to the supplier that identifies the 

chemical and indicates its percentage by weight in the product formulation. While the TRI reporting 

activity is not exactly analogous to the activity performed by the SNUR-regulated importer, work would 

be similar in that the company’s existing and available records would be examined to develop a set of 

entities. The U.S. EPA’s Economic Analysis of the Final Rule to Modify Reporting of Persistent 

Bioaccumulative Toxic Chemicals under EPCRA Section 313 (EPA, 1999) estimates the supplier 

notification burden to be 7 hours of technical staff time and 17 hours of clerical staff time per facility, 

regardless of facility characteristics. At the hourly wage rates listed in Table 2, the cost of this activity is 

approximately $952.

 Burden and Cost Associated with Activity 3: Identify all suppliers involved: 

 Approximately 24 hours and $952 for each importer, per rule. 

 Actual costs will vary depending on the number of articles imported, number of 

suppliers, and frequency of supplier changes. 
Internal Deliberative-- Do Not Cite or Distribute 19

5.2.4 Collect data from suppliers

Importers may obtain verification from suppliers identified in step 3 that the regulated chemical substance 

is not found in the article. A range of activities may be involved. As described above, methods may range 

from checking third-party certifications and declarations through databases or surveys, to developing 

individual agreements. At the extreme, importer companies may conduct a complete analysis of their 

supply stream. Choices on which method to use will likely vary depending on the level of experience of 

the importer. This section describes example scenarios of companies with different characteristics and the 

activities they may engage in. All possible methods are not described here; the intent is to capture the 

general range of possible activities and associated costs.

Otherwise-Regulated Importers

Companies that are currently subject to regulations such as REACH and RoHS or State regulations would 

likely use a database system, such as those described in Section 4.3. For example, companies such as 

Siemens, Philips, General Electric, Toshiba, Braun, V-tech, Olympus, and many others use BOMcheck 

(ENVIRON, n.d.). (Wal-Mart, 2012)-Mart uses GDSN to track chemicals in products. All major 

automobile manufacturers (e.g., Ford, General Motors) use IMDS (Hewlett-Packard Development 

Company, 2010). Some SNUR-regulated substances may already be monitored within these existing 

databases, and, given demand from the SNUR-regulated community, it is assumed that databases can be 

modified to include additional chemicals by the service provider.

Costs associated with gaining access to these databases are described in the box below; however, it is 

expected that importers who are experienced in complying with chemical restriction regulations will be

already using these services and thus, costs associated with registering or data management will already 

be incurred; therefore, these costs are considered baseline for “otherwise-regulated” importers. Costs 

associated with a new SNUR would be to run queries or otherwise gather data specifically related to the 

subject chemical.

Costs Associated with Various Database Services

The Global Data Synchronization Network (GDSN) Data Pool provider that is preferred by WalMart is 1SYNC, a subsidiary of GS1 US. Their annual membership fee schedule is indexed to a 

company’s total annual sales and is as follows: 

 <$1 million in annual sales, $625 annual fee; 

 $1 to <5 million sales, $1,225 annual fee; 

 $5 to <10 million sales, $1,750 fee; 

 $10 to <15 million sales, $2,250 fee; 

 $15 to <20 million sales, $2,700 fee; 

 $20 to <25 million sales, $3,400 fee; 

 $25 to <50 million sales, $4,600 fee; 

 $50 to <75 million sales, $7,600 fee; 

 $75 to <100 million sales, $10,625 fee; 

 $100 to <500 million sales, $14,575 fee; and 

 >$500 million in annual sales must contact 1SYNC for a price estimate (1SYNC, 2013a).

BOMcheck is a free service for manufacturers (i.e., importers), provided they agree to send a letter 

to their suppliers asking them to comply with regulatory requirements by joining BOMcheck

(ENVIRON, 2013c). For suppliers to register and use BOMcheck, there is an annual fee of about 

€300 (approximately $405) for companies with annual sales of greater than €3,000,000 

(~$4,012,800) and no annual fee otherwise (ENVIRON, 2013b).

Car manufacturers using IMDS must pay an initial fee of €100,000 ($133,760) when they join the 

system and an annual fee ranging between €100,000 and €500,000 ($133,760 to $668,800) to have 

access to the system (Kogg and Thidell, 2010).
Internal Deliberative-- Do Not Cite or Distribute 20

Not Otherwise-Regulated Importers

Importers finding themselves subject to a SNUR, with no previous regulatory experience related to 

chemical regulations or restrictions, may reach out to a trade association for support and guidance. For 

example, the Apparel and Footwear International RSL Management (AFIRM) Working Group provides a 

number of resources, such as a toolkit and guidance (AFIRM, 2011), that companies may find useful 

when focusing on supply chain management. Most industry sectors have their own specialized 

organizations that companies may use. For this analysis, we examined other possible activities that would 

likely be performed by two groups of “not otherwise-regulated” importers: large, complex-supply chain 

companies, and small, simple-supply chain companies. 

Large, Complex-Supply Chain Importers who are Not Otherwise Regulated

Large companies that have no experience in dealing with chemical restriction regulations (e.g., they do 

not operate in California or other states with restrictions on chemicals in articles, and do not import or 

operate in countries subject to REACH or RoHS) but that have a large number of suppliers may decide to 

register with one of the databases described above. Many retail chains already use GSDN for their global 

synchronization services with suppliers (1SYNC, 2013b). EPA believes that adapting the system similar 

to Wal-Mart’s use of it in tracking chemicals would be feasible within the fee schedule they are already 

paying. Joining BOMcheck is free for the importer company. (IMDS is specific to the automobile 

industry; this industry would likely fall under the “otherwise-regulated” category.) Costs specifically 

associated with any of these database services would be initial start-up costs in training staff in using 

them (or adapting an existing service as necessary), and to run queries or otherwise gather data 

specifically related to the subject chemical.

In the extreme case, companies with complex supply chains and abundant resources who are subject to 

SNURs and other environmental regulations may have an outside organization come in and review their 

entire chemical management program for environmental compliance and to “green” their supply chain. 

Consulting firms can develop a comprehensive supplier data collection method tailored to the company 

and all its regulatory needs. Costs can be significant; Intertek charges as much as $100,000 to $200,000 

for a full quality management system (Intertek Consumer Goods North America’s Andrew Wendinger, 

personal communication, February 8, 2013). Since this type of service would cover more regulatory 

requirements (and other environmental standards, as desired) than those imposed by a SNUR, costs for 

this level of effort are not considered here.

Small, Simple-Supply Chain Importers who are Not Otherwise Regulated

Small importer companies who are not experienced in complying with other chemical restriction 

regulations and who only have a few suppliers to contact may not desire to use a large database system 

due to their complexity and start-up costs. Simple-supply chain importers may have a closer, more 

trusting relationship with suppliers and may instead use individual agreements/certifications or 

questionnaires with them to ensure compliance with the SNUR. Formats for questionnaires or 

certifications may be available for free from industry associations (such as JIG for the electric and 

electronics sector (Consumer Electronics Association, 2012)), or they may develop their own. 

Another option for importers who only import a small number of products is to import only products that 

have been third-party certified, e.g., through organizations like Green Seal or Bluesign. The burden

associated with this option would include researching to determine if the certification includes a 

declaration or prohibition of the SNUR chemical and verifying whether imported articles are certified.

Cost Estimate

According to RPA (2003) (who based their analysis on a study performed by the Swedish Monitoring 

Board (2002)), the key cost for importers of articles in obtaining information on substances contained 

within articles is the staff time in obtaining information from suppliers. According to RPA’s analysis:
Internal Deliberative-- Do Not Cite or Distribute 21

some will already have systems of communication with suppliers that can be used to obtain such 

information. Nevertheless, it may be reasonable to assume that a time input of somewhere between five 

minutes per article type (where information is readily available) and eight hours per article type (where 

information has to be obtained from suppliers) might be required. (p. 34)

How frequently an importer may collect information from suppliers and which suppliers they would 

collect information from will vary depending on an importer’s experience complying with other 

regulations, available resources, and as due to a number of supply chain factors. Supply chains can 

change frequently. Importers may import multiple types of articles or models within a single product line 

(e.g., multiple models of athletic shoes from a single supplier) that may change over time. Importers may 

also use single or multiple suppliers for certain types of articles. Many of these changes can occur 

throughout an article supply chain prior to the article reaching the importer. These factors could all be 

considerations for the importer when deciding which articles to review for supplier information and how 

frequently.

For this analysis, we assume that the estimate of five minutes per article reviewed would correspond with 

companies who already have a system, such as a database, in place. They would simply need to retrieve 

the appropriate records. Therefore, the burden for otherwise-regulated importers is five minutes (0.08 

hour) of technical time per article type (about $5 at the hourly wage rate listed in Table 2Table 2). On the 

other hand, not otherwise-regulated, simple importers would need to spend the greatest amount of time 

per article reviewed, as they would likely use a method where they contact suppliers individually through 

questionnaires or other types of certification agreements. Therefore, we use the upper end of RPA’s 

estimate, 8 hours, for not otherwise-regulated, simple-supply chain importers (about $515 at the hourly 

wage rate listed in Table 2Table 2). The not otherwise-regulated, complex supply chain companies would 

likely incur a mid-range burden, approximately 4 hours (about $258 at the hourly wage rate listed in 

Table 2Table 2), to account for the start-up costs associated with beginning to use a database or other 

method as recommended by a trade association. 

 Burden and Cost Associated with Activity 4: Collect data from Suppliers:

 Approximately 0.08 hours and $5 for otherwise-regulated importers

 Approximately 4 hours and $258 for not otherwise-regulated, complex supply chain 

importers

 Approximately 8 hours and $515 for not otherwise-regulated, simple supply chain 

importers

 Costs are per article reviewed. Actual costs will vary depending on the specific data 

collection method chosen. Total costs depend on the number of articles the company 

may review. This number can vary based on factors such as the number of articles 

imported, number of suppliers, experience and familiarity with suppliers, and 

frequency of supplier changes or article changes (e.g., an article modification).

5.2.5 Chemical testing

In some cases, importers may have laboratory testing done on articles or components of articles to 

determine whether they contain the regulated chemical substance. It is likely that this would be done only 

when there is no other information available. Importers with a complex supply chain (many products) and

large companies (i.e., with the resources to do so) may test as an occasional compliance verification 

method in addition to other assurances from the supplier. The amount of testing performed may vary over 

time, and would likely depend on the number of suppliers, results of previous tests (i.e., based on the level 

of risk associated with a particular supplier), and changes in suppliers and articles imported.

An average test cost per article was estimated based on the pricing list for Elemental Analysis Test 

Information for Galbraith® Laboratories, Inc., a laboratory that provides testing of articles to support

compliance with Federal regulations including TSCA. This list included tests to identify various chemical 
Internal Deliberative-- Do Not Cite or Distribute 22

substances and elements. Prices ranged from $18 to $739 per sample, with an average of $128 over the 

630 tests priced. Additional fees may apply for sample preparation, such as for preparing an article.

 Cost Associated with Activity 5: Chemical Testing: 

 Approximately $130 per article tested. 

 Costs would likely only apply to large or complex supply chain importers with the 

resources to have testing done.

 Actual costs will vary depending on the specific chemical being tested for, the 

complexity of the article and sample preparation required, and the exact fees of the 

laboratory chosen for the analysis. Total costs per company will depend on the 

number of articles tested, which may be affected by the number of suppliers and risk 

associated with each, and frequency of supplier changes. 

5.2.6 Recordkeeping

If an importer subject to a SNUR chooses not to submit a SNUN (that is, the importer determines that 

imported articles do not contain the regulated chemical substance), it is assumed that the importer would 

maintain records of efforts made to evaluate the content of imported articles. It is assumed that that 

recordkeeping would be similar to that required when a SNUN is submitted (40 FR 721.40). Such 

recordkeeping essentially involves copying and filing relevant records, including those related to category 

of use and the maintenance of those records for five years from the date of their creation (40 CFR 

721.40). Economic Analyses for SNURs typically estimate this burden to be 0.15 hours of technical labor 

per rule (U.S. EPA, 2012), or $9.66 at the hourly wage rate listed in Table 2. Therefore, this paper 

estimates a similar burden. This cost would particularly be associated with companies that have no 

previous experience complying with chemical restriction rules; companies that already have methods in 

place to identify chemicals in articles likely already have recordkeeping systems in place.

 Burden and Cost Associated with Activity 6: Recordkeeping: 

 Approximately 0.15 hours and $10 per rule

5.3 Costs for Importer Company Scenarios

This section presents likely costs for four types of importer companies, in order to show the general range 

of costs that might be associated with removing the articles exemption for importers in SNURs. Costs are 

presented for: otherwise-regulated, large, complex-supply chain importers; not otherwise-regulated, large, 

complex-supply chain importers; otherwise-regulated, small, simple-supply chain importers; and not 

otherwise-regulated, small, simple-supply chain importers, in Table 3 through Table 6. Because some 

costs were estimated on a per rule basis, while others were estimated per article (based on the available 

data), total costs were not aggregated. Furthermore, the frequency of some of these activities may also 

vary in relation to others. 

Table 3. Costs associated with a large, complex-supply chain importer that is subject to other chemical 

restriction regulations

Activity Cost 

(2012$) Notes

Per Rule Costs

1. Rule familiarization $55 Cost typically already included in SNUR EAs

2. Identify the type of imported articles that 

potentially contain the restricted substances $1,550

Actual costs may vary based on number of articles 

imported and the complexity of the article itself 

(number of components)
Internal Deliberative-- Do Not Cite or Distribute 23

3. Identify all suppliers involved

$950

Actual costs may vary depending on the number of 

articles imported, number of suppliers, and frequency 

of supplier changes

6. Recordkeeping $10 Actual costs may vary depending on recordkeeping 

system already in place.

Article-Related Costs

4. Collect data from suppliers $5 per 

article 

reviewed. 

$0 if no 

data 

collected.

Actual costs only apply when companies collect data. 

They will vary depending on the specific data collection 

method chosen. Total costs depend on considerations 

including the number of articles imported, number of 

suppliers, and frequency of supplier changes, and 

whether or not the company has experience other 

existing regulations on SNUR regulated chemicals.

5. Chemical testing

$130 per 

article 

tested. $0 

if no 

testing.

Actual costs only apply to companies that test articles. 

They will vary depending on the specific chemical 

being tested for; the complexity of the article and 

sample preparation required; and the exact fees of the 

laboratory chosen for the analysis. Total costs per 

company will depend on the number of articles tested, 

which may be affected by considerations including the 

number of suppliers and risk associated with each, and 

frequency of supplier changes.

Table 4. Costs associated with a large, complex-supply chain importer that is not subject to other 

chemical restriction regulations

Activity Cost 

(2012$) Notes

Per Rule Costs

1. Rule familiarization $55 Cost typically already included in SNUR EAs

2. Identify the type of imported articles that 

potentially contain the restricted substances $1,550

Actual costs may vary based on number of articles 

imported and the complexity of the article itself 

(number of components)

3. Identify all suppliers involved

$950

Actual costs may vary depending on the number of 

articles imported, number of suppliers, and frequency 

of supplier changes

6. Recordkeeping $10 Actual costs may vary depending on recordkeeping 

system already in place.

Article-Related Costs

4. Collect data from suppliers $260 per 

article 

reviewed. 

$0 if no 

data 

collected. 

Actual costs only apply to companies that collect data. 

They will vary depending on the specific data collection 

method chosen. Total costs depend on considerations 

including the number of articles imported, number of 

suppliers, and frequency of supplier changes.

5. Chemical testing

$130 per 

article 

tested. $0 

if no 

testing.

Actual costs only apply to those companies that test 

articles. They will vary depending on the specific 

chemical being tested for; the complexity of the article 

and sample preparation required; and the exact fees of 

the laboratory chosen for the analysis. Total costs per 

company will depend on considerations including the 

number of articles tested, which may be affected by 

the number of suppliers and risk associated with each, 

and frequency of supplier changes.
Internal Deliberative-- Do Not Cite or Distribute 24

Table 5. Costs associated with a small, simple-supply chain importer that is subject to other chemical 

restriction regulations

Activity Cost 

(2012$) Notes

Per Rule Costs

1. Rule familiarization $55 Cost typically already included in SNUR EAs

2. Identify the type of imported articles that 

potentially contain the restricted substances $130

Actual costs may vary based on number of articles 

imported and the complexity of the article itself 

(number of components)

3. Identify all suppliers involved

$950

Actual costs may vary depending on the number of 

articles imported, number of suppliers, and frequency 

of supplier changes

6. Recordkeeping $10 Actual costs may vary depending on recordkeeping 

system already in place.

Article-Related Costs

4. Collect data from suppliers $5 per 

article 

reviewed. 

$0 if no 

data 

collected.

Actual costs only apply when companies collect data. 

They will vary depending on the specific data collection 

method chosen. Total costs depend on considerations 

including the number of articles imported, number of 

suppliers, and frequency of supplier changes, and 

whether or not the company has experience other 

existing regulations on SNUR regulated chemicals.

5. Chemical testing $130 per 

article 

tested. $0 

if no 

testing.

Assumed that small, simple-supply chain importers 

would not be likely to perform testing. Actual costs may 

be incurred depending on the perceived level of risk 

associated with suppliers.

Table 6. Costs associated with a small, simple-supply chain importer that is not subject to other 

chemical restriction regulations

Activity Cost 

(2012$) Notes

Per Rule Costs

1. Rule familiarization $55 Cost typically already included in SNUR EAs

2. Identify the type of imported articles that 

potentially contain the restricted substances $130

Actual costs may vary based on number of articles 

imported and the complexity of the article itself 

(number of components)

3. Identify all suppliers involved

$950

Actual costs may vary depending on the number of 

articles imported, number of suppliers, and frequency 

of supplier changes

6. Recordkeeping $10 Actual costs may vary depending on recordkeeping 

system already in place.

Article-Related Costs

4. Collect data from suppliers $515 per 

article 

reviewed. 

$0 if no 

data 

collected. 

Actual costs will only apply to those that collect 

information from suppliers. They will vary depending 

on the specific data collection method chosen. Total 

costs depend on considerations including the number 

of articles imported, number of suppliers, and 

frequency of supplier changes.

5. Chemical testing $130 per 

article 

tested. $0 

if no 

testing.

Assumed that small, simple-supply chain importers 

would not be likely to perform testing. Actual costs may 

be incurred depending on the perceived level of risk 

associated with suppliers.
Internal Deliberative-- Do Not Cite or Distribute 25

5.4 Summary

Certain SNURs may require importers or processors who import or process regulated chemical substances 

as part of articles to comply with notification requirements, such as notifying EPA at least 90 days before 

commencing the import of any articles containing chemicals subject to the rule. Additionally, if a SNUR

does not contain an exemption for processors and importers of articles, those that import or process 

articles may undertake activities to assure themselves that they are not importing or processing regulated 

chemicals as part of articles even though these activities are not required by the SNUR. A number of 

potential activities that importers may undertake to determine whether the articles they import contain 

regulated chemical substances are outlined in this paper. This determination may involve gathering 

information from suppliers in their supply chain, and/or testing samples of the article itself. 

Given the existing regulatory limitations on certain chemicals both internationally and within the U.S.,

regulated industries have begun to develop industry-wide processes and other resources to support such a 

determination. While there is still a great deal of variation among data collection methods, the set of 

activities that an importer would likely perform to identify any restricted chemicals in imported articles 

are as follows:

1) Understand applicable requirements. The importer would read and understand the SNUR, 

within the context of the company’s products. This burden is already accounted for in the 

standard economic analysis.

2) Identify the type of imported articles that potentially contain the restricted substances. This 

determination may be done based on an understanding of the uses of the restricted substance and 

the application of any a priori knowledge of the material and its manufacture to assess the 

probability whether each regulated substance may be present.

3) Identify all suppliers involved. The importer may identify suppliers from whom the articles 

identified in the previous step are imported, and as appropriate, to make them aware of the 

importer’s potential notice obligations respecting the regulated chemical substances.

4) Collect data from suppliers. Importers may obtain verification from suppliers identified in step 

3 that the regulated chemical substance is not found in the article. This may be accomplished 

through, for example, agreements with suppliers, declarations through databases or surveys, or by 

using a third-party certification system. 

5) Chemical testing. Importers may perform their own laboratory testing of certain articles (or 

components of articles) to determine if they contain the restricted substance. 

6) Recordkeeping. The importer may keep records confirming the activities completed. This burden 

is already accounted for in the standard economic analysis.

Variation in cost associated with these activities depends on a company’s level of baseline activity, the 

complexity of the supply chains; and the size of the company. The estimated range of costs for each of 

these activities is presented in Table 7. Total costs per importer will further depend on the number of 

affected articles and frequency of supplier change.
Internal Deliberative-- Do Not Cite or Distribute 26

Table 7. Range of costs associated with an importer’s identification of chemicals subject to SNURs in 

articles

Activity Cost 

(2012$) Notes

Per Rule Costs

1. Rule familiarization $55 Cost typically already included in SNUR EAs

2. Identify the type of imported articles that 

potentially contain the restricted substances $130 to 

$1,550

Actual costs may vary based on number of articles 

imported and the complexity of the article itself 

(number of components)

3. Identify all suppliers involved

$950

Actual costs may vary depending on the number of 

articles imported, number of suppliers, and frequency 

of supplier changes

6. Recordkeeping $10 Cost typically already included in SNUR EAs

Article-Related Costs

4. Collect data from suppliers $5 to $515

per article 

reviewed.

$0 if no 

data 

collected.

Actual costs only apply to those companies that collect 

data from suppliers. They will vary depending on the 

specific data collection method chosen. Total costs 

depend on considerations including the number of 

articles imported, number of suppliers, and frequency 

of supplier changes.

5. Chemical testing

$130 per 

article 

tested. $0 

if no 

testing.

Actual costs only apply to those companies that collect 

data from suppliers. They will vary depending on the 

specific chemical being tested for; the complexity of 

the article and sample preparation required; and the 

exact fees of the laboratory chosen for the analysis. 

Total costs per company will depend on considerations 

including the number of articles tested, which may be 

affected by the number of suppliers and risk 

associated with each, and frequency of supplier 

changes.

6 Costs (Processors)

To demonstrate compliance with a SNUR, it is expected that processors would most likely use the 

shipping or labeling documents received with the article in the ordinary course of business. Review of this 

documentation and flagging any chemicals subject to a SNUR or any other requirement are believed to be 

standard business practice. Additionally, since these documents would be received and stored as per 

standard business practices, the elimination of the exemption in SNURs for articles would likely incur no

significant additional costs to an article processor. (Minor costs for retrieving and photocopying the 

information if requested may apply.) Should paperwork show that a regulated chemical is part of an 

article, there may be some additional costs to the processor to ensure that the article is not processed.

Costs for submitting a SNUN would apply should the processor decide to submit one.

To the extent that processors undertake the steps to identify regulated chemicals outlined in Section 4.1

for importers, the costs of these activities would be similar to those outlined in Section 5.2 for importers 

of similar size, supply chain complexity, and level of compliance with other chemical regulations.

7 Limitations of Analysis

The values presented above provide a best estimate of the range of costs that may be incurred by 

importers and processors complying with SNUR requirements for imported articles, given the current lack 

of information and a standardized data collection system. As noted by Kogg and Thidell (2010):

It is obvious that designing [a system to track chemicals in products (CiP)] is a challenging and complex task 

including considerations of disparate and sometimes conflicting interests, levels of ambitions, etc. One central 

challenge facing those involved in the project of developing the CiP system, is the need to balance an 
Internal Deliberative-- Do Not Cite or Distribute 27

overwhelming complexity and heterogeneity of expressed needs for information (needs which the system 

should potentially satisfy), with strong preferences for harmonization.

These challenges similarly confound attempts at assessing cost. However, as the level of international 

regulation of chemicals does increase, industry groups and other organizations are working to develop 

comprehensive systems and processes. As systems standardize, at least within industry sectors, the 

likelihood of companies using consistent, streamlined methods of data collection increases and cost 

ranges will become clearer.
Internal Deliberative-- Do Not Cite or Distribute 28

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