Our Research and Analysis

CCI commissioned FTI Consulting, a well-respected global research firm, to analyze the real-world consequences of the TSCA Section 5 implementation policies the CCI wishes to change. A copy of the FTI analysis is available for download here.

The analysis shows that since TSCA reforms were signed into law in 2016 as the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg):

• R&D investment at CCI member companies has dropped from $324 million annually to $65 million annually, a stunning 80 percent reduction;
• Review times at EPA for new chemicals have more than doubled, and premanufacture notice review and approval time has increased from months to years; and
• Between 2017 and 2022, the time for getting new chemical determinations has increased from an average of 222 days to 608 days - almost two years.

The loss to the U.S. economy based on EPA’s failure to review new chemicals timely and companies’ resulting inability to commercialize new chemicals are noteworthy. Further, failing to replace older chemicals with new, more sustainable chemicals and EPA’s lengthy, cumbersome review process are driving up costs and delaying employing new chemicals that may address energy efficiency, water use, environmental degradation, environmental justice, and public health goals.

The CCI analysis accounts for the “upstream” losses to CCI members and their suppliers from lost sales opportunities, as well as the “downstream” losses to CCI members’ customers from lost sales and higher costs.

Forecasted upstream and downstream losses associated with the continued slow pace of EPA action for 2022-2026 include:

• 6,600 sustained job losses, on average;
• $10 billion in lost economic output;
• $4.2 billion in lost GDP;
• $2.3 billion in lost labor revenue for American workers; and
• Over $500 million in reduced federal tax revenues and nearly $300 million in reduced state and local tax revenues.

All of these important measures are counter to the stated goals of the BidenHarris Administration, and the lack of progress undermines the intent of the bipartisan Sustainable Chemistry Research and Development Act and the Infrastructure Investment and Jobs Act.

U.S. chemical companies are abandoning new, greener, more sustainable, more innovative chemicals or are shifting to markets outside of the United States as they develop work-arounds to the TSCA new chemicals review program to avoid the unpredictable, inconsistent, and glacially slow review times. The CCI seeks to turn this trend around and persuade EPA to adopt policies that incentivize new chemical innovation, not frustrate it.