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Revised CBI Substantiation Template for TSCA Section 5 Submissions

For Release: June 19, 2020

On June 19, 2020, EPA posted a revised confidential business information (CBI) substantiation template for TSCA section 5 submissions, including Premanufacture Notices (PMNs), Low Volume Exemptions (LVEs), and Significant New Use Notices (SNUNs). The revised template should help submitters understand the type of information that cannot be claimed as CBI under TSCA, facilitate the inclusion of information necessary to substantiate non-exempt CBI claims, and resolve an ambiguity with the previous template which allowed for different information types to be substantiated together.

Revisions to the template include:

  • Additional instructions pertaining to redacting attachments and CBI claims substantiation.
  • A new third column headed: “is this information claimed in an attachment.”
  • Consolidating section III of the template into one remaining field for “other information.” 
  • Clarifications that allow for information entered for "Protective Equipment/Engineering Controls (Part II Section A.2.3)" and "Physical Form(s) & % New Substance (Part II Section A.2.5)" to be substantiated separately.

More information on substantiating TSCA CBI claims and the revised template can be found at