Last Revised: December 05, 2022

Chemical Import Guidelines under TSCA

When purchasing chemicals from an international vendor, you may need to comply with TSCA requirements to get your shipment through U.S. Customs.  These guidelines provide an overview of how TSCA applies to typical chemical imports at Penn.

What is TSCA?

The Toxic Substances Control Act (TSCA) is a federal regulation authorizing the EPA to screen and regulate all chemicals produced or imported into the United States.

Purchasing chemicals from international suppliers

When purchasing chemicals from an international supplier, the vendor will require you to complete a TSCA Import Certification form.  Research staff should complete and sign this form which provides basic contact information, a description of what is being purchased and you must indicate a positive or negative certification.  If the vendor does not supply a form, a blank form can be found here.  

Most chemical purchases at Penn for research purposes will get a “Positive Certification.” This indicates that the chemicals fall under TSCA regulation but are exempt from most requirements under the Research and Development Exemption.  To qualify for the R&D exemption, chemicals must be:

  • Imported only in small quantities, and
  • Used solely for purposes of non-commercial scientific experimentation, analysis, or research, and
  • Under the supervision if a technically qualified individual

Chemicals not subject to TSCA regulation                                   

If your chemical import falls into one of the following categories, it is not regulated under TSCA, and the “Negative Certification” box should be checked on the form.

  • Pesticides regulated under FIFRA
  • Tobacco and tobacco products regulated by the ATF
  • Radioactive materials regulated by the NRC
  • Foods, food additives, drugs, and cosmetics regulated by the FDA

Additional information can be found on the EPA website.