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October 16, 2018

Inside EPA Quotes B&C’s “EPA Issues Final TSCA Fees Rule” Memorandum

The ACTA Group

On October 16, 2018, Inside EPA quoted The Acta Group (Acta®) affiliate Bergeson & Campbell P.C.’s (B&C®) memorandum “EPA Issues Final TSCA Fees Rule” in the article “EPA finalizes TSCA fees rule but legal challenges possible.”

A Sept. 28 memo from the law firm Bergeson & Campbell notes that “the final rule will apply to all submissions that are received starting October 1, 2018. EPA stated that it will invoice affected companies within 30 days of the effective date.”


Bergeson & Campbell in its memo “appreciate[s] the regulatory and administrative coherence afforded by adopting the SBA’s approach. The SBA is also required by statute to periodically review and adjust its size standard to help keep the standard current with industry and market conditions. This will hopefully set the stage for periodic review by EPA . . . as part of the TSCA requirement to review fees every three years.”

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