EPA v. COMPASS CHEMICAL INTERNATIONAL, LLC

Case summary

JULY 29, 2026 - CONSENT AGREEMENT On February 13, 2024, the EPA issued a Notice of Inspection notifying Respondent that the EPA would be conducting an inspection at Respondent's Facility pursuant to Section ll(a) of TSCA, 15 U.S.C. ? 2610(a), to evaluate Respondent's compliance with TSCA. In response to the Notice of Inspection, on March 4, 2024, Respondent submitted certain records to the EPA pertaining to its manufacture and domestic purchase of chemicals. On March 6, 2024, the EPA conducted the inspection at Respondent's Facility. On July 9, 2025, after reviewing the production records submitted by Respondent, the EPA issued Respondent an Opportunity to Show Cause letter alleging that Respondent had potentially violated Sections 4, 8, and 15 of TSCA, 15 U.S.C. ?? 2603, 2607, and 2614, by failing to comply with the CDR requirements found in 40 C.F.R. Part 711, and by failing to comply with the testing requirements found in 40 C.F.R. Part 799. On August 4, 2025, Respondent provided a response to the Show Cause Letter. Chemical Data Reporting for Chemicals D, F, and G [CBI redacted] Records submitted by Respondent included production records from 2020-2023, indicating that Respondent manufactured a reportable quantity (greater than 25,000 pounds) of Chemicals D, F, and G for commercial purposes from 2020-2023. Chemicals D, F, and G were in the TSCA Master Inventory File at the beginning of a submission period described in 40 C.F.R. ? 711.20 and were not chemical substances specifically excluded from the CDR reporting requirements by 40 C.F.R. ? 711.6. Pursuant to 40 C.F.R. ? 711.15, Respondent was required to submit a 2024 CDR Report to the EPA for reportable chemical substances that were manufactured (including imported) for commercial purposes in quantities greater than 25,000 pounds in calendar years 2020, 2021, 2022, and 2023 by no later than the end of the 2024 CDR submission period, which was November 22, 2024. Chemicals D, F, and Gare reportable chemical substances manufactured by Respondent during the 2024 CDR submission period (2020-2023) and are therefore subject to the 2024 CDR reporting requirements. Respondent did not submit a CDR Report for Chemicals D, F, and G by November 22, 2024, the last day of the 2024 CDR submission period. Intent to Test or Exemption from Testing for Chemical H Based on Respondent's 2020-2023 production records, Respondent manufactured five batches of Chemical H from 2021-2023. On [CBI redacted], the EPA promulgated a final TSCA Section 4 Test Rule for Chemical H. The effective date of Chemical H's final test rule was [CBI redacted]. During the production period, Chemical H was subject to a test rule promulgated pursuant to Section 4 of TSCA and 40 C.F.R. ? 799.5089. Based on the production dates, Respondent was required to submit a letter of intent to test or an exemption from testing application to the EPA for Chemical H no later than May 5, 2021, which was the date of Respondent's first manufacture of Chemical H. Respondent failed to submit a letter of intent to test or an exemption from testing for Chemical Hon or before May 5, 2021. Respondent consents to the payment of a civil penalty, which was calculated in accordance with the Act, in the amount of ONE HUNDRED TWELVE THOUSAND SEVEN HUNDRED DOLLARS ($112,700.00), which is to be paid within thirty (30) days of the Effective Date of the CAFO.

Defendants (1)

• COMPASS CHEMICAL INTERNATIONAL, LLCNamed in complaintNamed in settlement

Facilities (4)

• COMPASS CHEMICAL INTERNATIONAL, LLC

  5544 OAKDALE RD SE, SMYRNA, GA, 30082

  Registry ID: 110015326869

• COMPASS CHEMICAL INTERNATIONAL, LLC

  5544 OAKDALE RD SE, SMYRNA, GA, 30082

  Registry ID: 110015326869

• COMPASS CHEMICAL INTERNATIONAL, LLC

  5544 OAKDALE RD SE, SMYRNA, GA, 30082

  Registry ID: 110015326869

• COMPASS CHEMICAL INTERNATIONAL, LLC

  5544 OAKDALE RD SE, SMYRNA, GA, 30082

  Registry ID: 110015326869

Statutes cited

• TSCA 8 — Reporting & Retention of Information
• TSCA 4 — Testing of Chemical Substances and Mixtures

Enforcement conclusions (1)

• COMPASS CHEMICAL INTERNATIONAL, LLCentered 2026-07-29

  Primary law: TSCA

  Federal penalty: $112,700

Timeline (3 milestones)

• 2026-07-29Final Order Issued
• 2026-07-29Complaint Filed/Proposed Order
• 2026-08-06Enforcement Action Data Entered