Who is subject to the upcoming obligation to self-identify as a manufacturer of a high-priority substance and pay a portion of a fee of more than a million dollars under EPA’s Toxic Substances Control Act (TSCA) fees rule?  Many companies who may be unaware of that obligation, including many importers of finished products, such as electronics or products made with composite wood. EPA has initiated risk evaluations of 20 high-priority substances. Companies that “manufactured” any of those substances in the past five years must comply with EPA’s fees rule, 40 C.F.R. Part 700, Subpart C, adopted under TSCA § 26(b). Such a company has until: March 27, 2020 to identify itself as a manufacturer of each of the 20 high-priority substances (possibly as an importer of articles that contain any of those substances) that it manufactured since January 27, 2015. Sometime around June 20, 2020 to see the final lists of companies responsible for sharing the costs of the fees for the substances that it manufactured. For these purposes, “manufacture” includes, among other activities, domestic synthesis or import of chemical substances as byproducts or impurities, for research and de...