In the UV materials market, misconceptions about SNURs can compromise formulators’ competitive technical edge by limiting the scope of their potential innovation.
Since their introduction, SNURs have been cast in a negative light. This guide will help you rethink your product development and formulating options so you can stay ahead of your competition.
SNURs (Significant New Use Rules) are policies that the EPA assigns for certain chemicals, impacting potential commercial use through the introduction of usage requirements.
No! The EPA reviews chemicals and determines whether a SNUR will be applied. Some SNUR requirements may directly overlap with typical manufacturing and safety practices (use of personal protective equipment) while others may have separate and / or additional requirements (manufacturing and importation volume limits, specific approved use case[s], etc.)
Chemicals with SNURs should be reviewed case by case to assess their fit for your intended use. In some cases, SNUR requirements are fulfilled by simply following standard manufacturing and safety procedures. Other SNURs may require more effort to ensure compliance but the additional time and resource investment to do so may still be manageable.
You can reduce restrictions or expand approved use cases by filing SNUNs (Significant New Use Notifications) and providing new relevant test data to support such proposals. Ultimately there still may be products with SNURs too restrictive for your intended use, but a case by case review is worthwhile given the number of potential successes.
In recent years, significantly more chemicals have received SNURs and this trend is expected to continue for years to come.
Blanket dismissal of raw materials with SNURs without proper review can compromise formulators’ competitive technical edge by limiting the scope of their potential innovation. Eventually competition can bridge the gap or surpass peers who choose not to pursue such novel technologies purely due to SNUR status.
Since 2016,
Of reviewed substances have received SNURs*
*727 consent orders/SNURs out of 1,825 substances reviewed.
Source: epa.gov
Are you considering materials with SNURs and wondering how to handle them, or want to reduce the restrictions or expand approved use cases (SNUNs)? Reach out to your NBS specialist to discuss further and let our regulatory experts assist you.
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