👥 Who must comply

• Manufacturers (including importers) and processors planning to engage in the designated significant new use.
• Sellers must notify downstream users of the SNUR status; buyers of confidential-identity substances should obtain supplier certification that the intended use is not a significant new use.

🔎 Step 1 — Confirm SNUR applicability (fast, reliable screening)

1) Check the TSCA Inventory “S” flag

EPA uses regulatory flags in the TSCA Inventory; “S” indicates a substance identified in a final SNUR (and “SP” indicates a proposed SNUR).

2) Identify the exact SNUR text that applies

SNUR requirements are implemented through 40 CFR Part 721 (with chemical-specific SNURs typically listed in Subpart E).

What we do in this step

• Map your substance identity (CAS / accession / generic name) to the correct Part 721 entry.
• Verify whether any SNUR provisions modify general Part 721 rules for your specific substance.

🧭 Step 2 — Determine whether your planned activity is a “significant new use”

A SNUR is triggered only when your planned activity matches the SNUR’s significant new use definition. Common trigger patterns include:

• Change in use category (e.g., consumer vs. industrial)
• Change in physical form or application method affecting exposure
• Volume increases that alter exposure magnitude/duration
• Use without specified engineering controls / PPE / hazard communication elements

How to make this defensible

• Document your “conditions of use” (who, what, where, how, how much).
• Compare them point-by-point to the SNUR’s trigger language and the exposure/volume factors EPA highlights under Section 5(a)(2).

🧾 Step 3 — Build a SNUN-ready dossier (what to compile before filing)

A strong SNUN package is built around a clear, auditable story: identity → conditions of use → exposure controls → supporting data.

📦 SNUN dossier checklist

🧪 Substance identity & composition

• Substance identity (CAS/structure or accession/generic name)
• Composition, impurities, stabilizers, and analytical support

🏭 Manufacturing / processing

• Process description, sites, operational parameters, volume ranges
• Worker task breakdown + exposure routes

🌎 Releases & waste

• Air/water/solid release points and controls
• Waste handling and disposal method

👷 Worker communication & controls (when referenced by SNUR)

• If your SNUR relies on 40 CFR 721.72, you need a written hazard communication program for the substance in each workplace.

📎 Supporting information

• Assemble any relevant hazard/exposure information you have or can reasonably obtain so the notice is complete and consistent with EPA expectations for SNUN review.

📤 Step 4 — File the SNUN correctly (format + channel + content)

✅ Electronic submission requirements

• SNUNs are reported using the standard e-PMN form and undergo a 90-day review process similar to a PMN.
• Prepare a cover letter that includes the CFR citation of the SNUR and identifies the specific significant new use(s) being noticed.
• To submit electronically, complete forms in e-PMN software and submit through EPA CDX (CSPP service); users must register in CDX.

🤝 Joint SNUNs (optional)

Two or more required submitters may submit a joint SNUN, but each party must complete required certifications and remains responsible for information within its control.

⛔ Step 5 — Control “no-start” timing (prevent accidental violations)

Create a simple internal release gate: no import / manufacture / processing for the significant new use until the SNUN pathway is cleared. This aligns with SNUR’s purpose: EPA review before the activity occurs.

🗃️ Step 6 — Recordkeeping (audit-ready by design)

SNUN documentation must be retained for 5 years from the date of SNUN submission (recordkeeping requirement).

Best-practice retention set

• SNUR applicability evidence (inventory flag + rule citation)
• Significant new use determination memo (decision + sign-off)
• SNUN dossier (all submitted fields + attachments)
• Submission confirmation and EPA communications
• Any post-submission changes and corrective actions

🎁 Deliverables of this service

✅ SNUR applicability screening (TSCA Inventory flags + Part 721/Subpart E mapping)

✅ Significant new use determination (documented, repeatable decision logic)

✅ SNUN dossier build (submission-ready package)

✅ e-PMN/CDX filing readiness (form structure + cover letter content)

✅ Hazard communication readiness where 721.72 applies

✅ 5-year recordkeeping framework

🚫 Common issues we eliminate

• Missing SNUR triggers because the change was “only” volume, form, or exposure controls (exactly what Section 5(a)(2) focuses on).
• Filing a SNUN without a clear SNUR citation + significant new use identification in the cover letter.
• Weak workplace documentation when hazard communication program elements are implicated.
• Missing or disorganized retention, creating inspection risk.

⭐ Why ComplyMarket is the best-ever solution for TSCA Section 5(a)(2) compliance

ComplyMarket delivers an integrated Material Compliance management and reporting platform that turns SNUR/SNUN obligations into a controlled, auditable workflow—so teams can detect SNUR triggers early, standardize “significant new use” decisions, assemble SNUN-ready dossiers, and retain evidence for audits without relying on scattered spreadsheets and email chains.

🚀 How ComplyMarket supports TSCA 5(a)(2) in practice

• SNUR detection workflows across materials, mixtures, and products (with change-event triggers like new use, new form, volume increase, new site).
• Use-mapping & decision control to compare “conditions of use” against SNUR trigger language with approvals and traceability.
• SNUN dossier management (structured data capture + attachments + versioning) aligned to e-PMN expectations.
• Hazard communication governance to track workplace program elements, SDS/label controls, and supporting evidence when relevant.
• Audit-grade recordkeeping with retention controls, permissions, and rapid retrieval for inspections.

ComplyMarket makes TSCA Section 5(a)(2) compliance repeatable and scalable—reducing missed triggers, rework, and audit risk while speeding confident market access.