Consumers, Industry, and Researchers Agree: TSCA Needs Reform  

Industry representatives at the American Chemistry Council's (ACC) GlobalChem 2026 conference called for a faster and more predictable U.S. chemical-review process. A recent ACC-commissioned survey found public support for maintaining health and environmental protections while making regulatory reviews more efficient and predictable.

The survey, conducted by Morning Consult on behalf of the ACC, found “broad support for maintaining health and environmental protections while also improving efficiency, predictability, and competitiveness,” the ACC told 3E. The online poll surveyed 3,009 U.S. adults from August 19–29, 2026. The results were weighted to national demographics and have a margin of error of plus or minus 2 percentage points. About 69% of respondents agreed that practical policies can protect health and the environment without sacrificing manufacturing jobs and U.S. competitiveness. Meanwhile, 65% said more predictable regulatory processes and timelines were a convincing reason to update the Toxic Substances Control Act (TSCA), while 71% said it was important for EPA to complete new chemical reviews within the statutory 90-day review period while maintaining rigorous safety standards.

To examine the industry concerns underlying calls to update TSCA, 3E spoke with John Hott, a longtime chemical industry professional who is vice president of strategic accounts at 3E. He said the central concern is that the U.S. Environmental Protection Agency's (EPA) safety-review process has become too slow and unpredictable.

“The EPA does a great job at their safety assessment to the point that it's a very conservative assessment,” Hott said. But he argued that we are “sacrificing the time to market” because of the length of those reviews. Hott said a process intended to take 90 days can instead stretch to one to two years or more. The issues that slow down the process focus on the lack of a clear process for EPA reviews, the conservative modeling the agency relies on, and a deficit of proper resources.

Lack of Predictability

The ACC survey highlights predictability as a central concern among the public and that was reflected by the industry leaders at GlobalChem. Hott also repeatedly identified the issue of unpredictability in the TSCA review process as one of the key areas of concern.

He contrasted the U.S. system with the EU regulatory system, which he characterized as more predictable because manufacturers can determine in advance what studies and information will be necessary. That allows companies to better prepare those materials before submitting them under the EU regulatory scheme. Under TSCA, manufacturers do not always have an equally clear roadmap for what data may be ultimately required by the EPA or how the agency will use the data in their risk assessments.

“There isn't a set equation for approving that chemistry,” Hott said. He added that one of the major obstacles for predictability is that without a clear process for risk assessments, they can be performed differently depending on different assessors and their respective management.

Hott pointed to the EPA's pesticide program under the Federal Insecticide, Fungicide, and Rodenticide Act as a possible model for an updated TSCA. On the pesticide side, Hott said, applicants know which studies are required, how those studies will be incorporated into the risk assessments, and what criteria a product needs to satisfy.

“On the chemical side, we need that same rigidity that you know what's going to be required,” he said. Clear requirements, he emphasized, could make the process more efficient both for companies preparing submissions and for EPA reviewers and management assessing them.

Conservative Modeling

Hott also identified the EPA's use of modeled data as another area where industry has pushed for changes. He said manufacturers can spend millions of dollars conducting toxicology studies on a new chemical, only to have the results of those studies disregarded by the EPA. Instead, the agency may rely on “modeled” results if they are more conservative than an actual toxicological study. One reform favored by industry would give actual study data greater weight when both empirical and modeled information are available.

Hott also pointed to progress within the agency, particularly its movement toward new approach methodologies, including non-animal testing. He described those developments positively but said they have not resolved what he views as the broader problem of backlogs and delayed reviews.

“The agency is moving in a good direction,” Hott said, but “not at the speed” needed to address those delays.

The issue of the EPA using modeling data over real-world experiments was at the forefront of the ACC's concerns with the agency's final risk evaluation for formaldehyde, released in 2024. The ACC argued that the risk evaluation did not fully align with statutory requirements for scientific quality and relied too heavily on the EPA's Integrated Risk Information System (IRIS) program.

“As a result, a flawed evaluation may lead to regulations that are more restrictive than necessary for this important chemistry, with potential implications for the U.S. economy and domestic production,” the ACC said in a statement.

In December 2025, the EPA released updated draft risk calculations for public comment while maintaining its determination that formaldehyde presents an unreasonable risk under its conditions of use. The ACC welcomed the updated analysis and the agency's decision to “reevaluate key scientific inputs” in the risk evaluation.

“EPA's updated draft analysis incorporates important scientific principles long supported by the [ACC Formaldehyde] Panel and other scientific bodies,” said the ACC. “These updates help align the TSCA process with the best available science and improve the scientific foundation of EPA's evaluation.”

Speed vs. Safety

By fixing these issues with predictability and using proper science to generate risk evaluations, the hope is that the EPA will be able to make its risk evaluations within the statutory 90-day period. While some may be concerned that efforts to change the way the agency does risk evaluations to make the process faster may harm public health, the ACC survey rejects the idea of a “false choice” between chemical safety and competitiveness.

Hott similarly argued that faster reviews do not necessarily require weaker safety standards. But he said there could be risks if the EPA were forced to meet statutory deadlines without having enough resources to conduct adequate reviews.

“The concern would be if the agency were to allow reviews to go forward without actually doing the work,” he said. “If they had to meet the 90 days and didn't have the amount of resources they needed to do the reviews, that's where the risk is.”

Hott said industry would instead argue that the EPA should prioritize resources toward its required chemical-review responsibilities. He also noted that the agency has not simply sacrificed safety reviews to meet deadlines.

The consequences of not making the process faster are already playing out, according to Hott. Delays in the review process can affect decisions about where companies manufacture products, he said. If a company can obtain authorization and begin supplying global markets from another jurisdiction sooner, it may choose to locate production there rather than wait for U.S. approval.

“You can't manufacture it until you have approval,” Hott said. “So, then you're going to place that manufacturing somewhere else because you're not going to wait.”

The ACC survey separately found public support for timely EPA reviews that maintain rigorous safety standards.

“Respondents were asked about the importance of EPA completing reviews within the 90-day statutory timeframe while maintaining a rigorous safety review process. These findings indicate that Americans view protecting health and the environment as an important priority and generally support approaches that balance those protections with efficient regulatory processes and a competitive domestic manufacturing base,” the ACC told 3E.

For Hott and industry leaders, the goal of TSCA reform is much the same: Make the review process faster and more predictable without sacrificing safety. Whether that can be accomplished will depend on changes to the EPA's review process and on whether the agency has the resources needed to complete those reviews within the timelines required by law.