EPA v. NEXUS CIRCULAR, LLC

Case summary

3/12/2026 - CONSENT AGREEMENT AND FINAL ORDER ISSUED ASSESSING A PENALTY OF $40,700.00 DUE WITHIN 30 DAYS AFTER THE EFFECTIVE DATE OF THIS CAFO. ALLEGED VIOLATIONS: ON APRIL 23, 2024, THE EPA SENT RESPONDENT A NOTICE OF INSPECTION NOTIFYING RESPONDENT THAT THE EPA WOULD BE CONDUCTING AN INSPECTION AT RESPONDENT?S FACILITY PURSUANT TO SECTION 11(A) OF TSCA, 15 U.S.C. ? 2610(A), TO EVALUATE RESPONDENT?S COMPLIANCE WITH TSCA. ON JUNE 4, 2024, AUTHORIZED AGENTS OF THE EPA CONDUCTED THE INSPECTION AT RESPONDENT?S FACILITY. ON MAY 17, 2024, AND JUNE 6, 2024, RESPONDENT SUBMITTED THE RECORDS REQUESTED IN THE NOTICE OF INSPECTION, INCLUDING INFORMATION PERTAINING TO ITS MANUFACTURE, PROCESSING, EXPORTATION, AND IMPORTATION OF CHEMICALS. IN RESPONSE TO THE OPPORTUNITY TO SHOW CAUSE LETTER DATED OCTOBER 1, 2024, ON NOVEMBER 7, 2024, RESPONDENT SUBMITTED ADDITIONAL INFORMATION TO THE EPA, INCLUDING INFORMATION RELATED TO THE EXPORT OF TWO CHEMICALS TO SEVERAL COUNTRIES. BASED ON THE EPA?S INVESTIGATION, INCLUDING A REVIEW OF RESPONDENT?S RECORDS AS SET FORTH IN THIS CAFO, THE EPA ALLEGES THAT RESPONDENT FAILED TO SUBMIT TSCA SECTION 12(B) EXPORT NOTICES TO THE EPA FOR CHEMICALS A AND B WITHIN SEVEN DAYS OF FORMING AN INTENT TO EXPORT OR ON THE DATE OF EXPORT FOR THE FIRST EXPORT OF EACH OF THE CHEMICALS, IN VIOLATION OF 40 C.F.R. ?? 707.60(A), 707.65(A)(1)(II), AND 707.65(A)(2), AND SECTIONS 12(B) AND 15 OF TSCA, 15 U.S.C. ?? 2611(B) AND 2614, AS SET FORTH IN SECTION IV OF THIS CAFO.

Defendants (1)

• NEXUS CIRCULAR, LLCNamed in complaintNamed in settlement

Facilities (1)

• NEXUS CIRCULAR, LLC

  500 WATERFRONT DR SW, ATLANTA, GA, 30336

  Registry ID: 110070106050

Statutes cited

• TSCA 12 — Exports

Enforcement conclusions (1)

• NEXUS CIRCULAR, LLCentered 2026-03-12

  Primary law: TSCA

  Federal penalty: $40,700

Timeline (3 milestones)

• 2026-03-12Complaint Filed/Proposed Order
• 2026-03-12Final Order Issued
• 2026-03-16Enforcement Action Data Entered