On December 10, 2020, the U.S. Environmental Protection Agency (EPA) released a draft guidance for imported articles that may contain long-chain perfluoroalkyl carboxylate chemical substances (LCPFAC), a subgroup of certain per- and polyfluoroalkyl substances (PFAS), as part of a surface coating and that would be subject to its Significant New Use Rule (SNUR) if a manufacturer seeks to resume using them. In response to calls to define surface coating, EPA provided two guidelines: (1) coating on any surface of an article that is in direct contact with humans or the environment during the article’s normal use or reuse, whether the coating is oriented toward the interior or exterior of the article, or (2) coating on any internal component, even if facing the interior of the article, if that component is in contact with humans or the environment during the article’s normal use or reuse. EPA also includes a “non-exhaustive list” of potential articles that may use LCPFAC chemical substances in surface coatings, including apparel, furniture, paper goods, automotive parts, carpets, and lightbulbs. EPA expects the guidance to be released for public notice and comment in December.
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