There is a mistaken perception that the U.S. Environmental Protection Agency (EPA) is not aggressively enforcing U.S. chemical laws. It is. EPA announced on June 1, 2026, that it filed an administrative complaint against Wego Chemical Group and related companies (Wego) for violations of the Toxic Substances Control Act (TSCA). If EPA seeks maximum penalties, it could yield a whopping $34 million penalty. The complaint, and others like it, reflect the agency’s commitment to blunt illegal imports of chemicals. This article discusses the action and EPA’s tough stance on noncompliance. 

Background

The complaint reportedly results from Wego’s “years-long” failure to properly report its imports and domestic distribution of chemical substances. EPA states that since at least 2016, Wego imported “hundreds of millions of pounds of hundreds of toxic chemicals, mostly from China, without meeting basic federal reporting requirements.” Wego initially failed to submit its required 2020 Chemical Data Reporting (CDR) submission, and once it did submit its CDR data, “it omitted required information on how any of the chemicals will be used, information that EPA needs to evaluate public health risks.”

The complaint alleges eight categories of TSCA violations, “reflecting a sustained pattern of failing to report, notify and certify as required by law.” EPA alleges, among other claims, that Wego failed to submit timely CDR data for hundreds of chemicals across two reporting cycles; never reported required use information for those chemicals in either submission; failed to submit a premanufacture notification (PMN) before importing a new chemical substance; failed to file a required TSCA compliance certification at the time it unlawfully imported that new chemical; failed to submit significant new use notices (SNUN) as required; and failed to notify EPA of the export to Canada of two chemicals that were subject to significant new use rules (SNUR).

EPA began its investigation into Wego’s TSCA compliance in May 2021. The administrative complaint initiates the formal enforcement process. TSCA penalties are high and EPA seeks the following civil penalties: 

• Count 1: TSCA Section 8(a): Failure to submit 2020 Form U for 209 reportable chemical substances. EPA seeks a penalty of up to $49,772 for each of the 209 chemicals listed in the 2020 Form U that Wego failed to timely submit;
• Count 2: TSCA Section 8(a): Failure to submit 2020 Form U chemical data report for five reportable chemical substances. EPA seeks a penalty of up to $49,772 for each of these five chemical substances listed in the 2020 Form U that Wego failed to timely submit;
• Count 3: TSCA Section 8(a): Failure to report required information in 2020 Form U. EPA seeks a penalty of up to $49,772 for each of the 209 chemical substances for which Wego failed to report required information;
• Count 4: TSCA Section 8(a): Failure to report required information in 2024 Form U. EPA seeks a penalty of up to $49,772 for each of the 247 chemical substances for which Wego failed to report required information;
• Count 5: Seven PMN Violations. EPA seeks a penalty of up to $49,772 for each of the seven alleged PMN violations; and
• Count 6: Failure to provide requisite TSCA certifications for TSCA importations: EPA seeks a penalty of up to $49,772 for each of the seven alleged certification violations.

Discussion

If the 684 counts hold and maximum penalties are sought, EPA’s enforcement matter against Wego could yield a massive $34 million penalty for alleged violations of TSCA — the vast majority of which involve violations for lack of reporting under EPA’s CDR rule. The case is unique for the number of alleged violations, but definitely not for the type of alleged violations. It is yet another example of EPA targeting imports. EPA announced on Dec. 23, 2025, that it would be “dramatically expanding its imports investigative capacity and enforcement scope.” Earlier this year, EPA also announced its enforcement and compliance numbers for Fiscal Year 2025, including various actions imports, touting an “unprecedented commitment to helping secure the border” through collaboration with federal law enforcement agencies and U.S. Customs and Border Protection at ports of entry and training of enforcement personnel on the “detection and interdiction of dangerous substances and illegal imports.”

Importers of chemicals and pesticides should take note. Companies that import chemical substances or pesticides subject to TSCA or the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requirements would be wise to consider revisiting compliance strategies and standard operating procedures and ensuring robust documentation to avoid penalties and substantial negative publicity.