US EPA issues notice on upcoming TSCA CBI expirations – Immediate action required

The US Environmental Protection Agency (EPA) has now issued a formal notice detailing how it will implement the TSCA Confidential Business Information (CBI) expiration and extension process. As part of this effort, on April 24, 2026, EPA published a publicly accessible list of TSCA submissions with CBI claims scheduled to expire between June 22, 2026, and July 31, 2026.

This reflects EPA’s implementation of the 10 year CBI expiration requirement under the 2016 TSCA amendments. Without a timely extension request and successful re-substantiation, impacted CBI claims will expire, making the information eligible for public disclosure.

Companies with TSCA submissions containing non exempt CBI claims should act now to assess their exposure, confirm upcoming deadlines, and prepare the required documentation to maintain confidentiality protections.

Who is impacted?

Any company that asserted non exempt CBI claims in TSCA submissions on or after June 22, 2016, including claims covering chemical identity and other protected information, may be affected.

EPA notification process

EPA will notify submitters at least 60 days prior to CBI claim expiration, and more specific instructions for submitting extension requests will be made available prior to publication of the initial CBI claim expiration notices. Failure to act will result in the information becoming eligible for public disclosure.

What is required to maintain CBI claims?

To extend a CBI claim beyond the 10 year period, companies must:

• Submit a timely extension request (no later than 30 days prior to the expiration date of the claims)
• Provide a complete re-substantiation demonstrating that the information still qualifies for protection under TSCA Section 14.

EPA will review each request and determine whether confidentiality will be maintained.

Key exemptions

Some categories of information remain exempt from expiration requirements; however, most chemical identity claims are subject to expiration once the substance is in commerce.

How Sagentia Regulatory can help

As EPA begins implementing CBI expirations, companies face short response windows and the risk of unintended public disclosure. Sagentia Regulatory (formerly TSG Consulting) supports companies across the key TSCA compliance steps, including:

• Reviewing and identifying the TSCA submissions made since June 22, 2016 that include non‑exempt CBI claims
• Monitoring EPA notifications closely
• Preparing re‑substantiation documentation in advance of EPA deadlines