Clariant admitted violations of section 5 ofTSCA, 15 U.S.C. § 2604, and section 15 of
TSCA, 15 U.S.C. § 2614. Specifically, Clariant failed to submit a premanufacture
notification (PMN) to the EPA Administrator, as required by 40 C.F .R. Part 720,
regarding the Company's intention to manufacture a new chemical substance. This
failure constituted violations of TSCA sections 5(a)(l), 15(1)(B) and 15(3)(B). 15 U.S.C.
§§ 2604(a)(1), 2614(l)(B), and 2614(3)(B). Clariant also disclosed that it violated
TSCA section 8(a), the Notice ofCommencement (NOC) regulations, when it failed to
submit a Notice of Manufacture or Import for one chemical substance no later than 30
calendar days after the date it first manufactured or imported the new chemical for
commercial purposes and the TSCA 8( e) reporting requirements when Clariant failed to
submit to EPA two acute rat inhalation studies involving a chemical substance that had
not been previously reported to the Agency as required by TSCA section 8(e).