BASF submitted a voluntary report pursuant to EPAÂs Audit Policy disclosing violations of Sections 5 and 13 of the Toxic Substances Control Act (TSCA) and its implementing regulations regarding premanufacture notification and import certification. This voluntary report did not meet the Âno repeat violations condition of the Audit Policy. BASF had previously disclosed TSCA Sections 5 and 13 violations within the last 3 years. It was determined that a gravity-based penalty would be assessed in this case. Subsequent to the disclosure, BASF submitted the premanufacture notification.