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Colgate-Palmolive Agrees to Pay $930,000 Over a Report Covering 47 Chemicals

Chemical reporting and regulatory oversight

The report was due in January 2021. Colgate-Palmolive submitted it in July 2023, after an EPA inspection and records request.

What the order establishes

  • A Chemical Data Reporting form covering 47 imported substances was due by January 29, 2021.
  • EPA found that Colgate-Palmolive had not filed the form when the agency inspected a New Jersey facility on March 30, 2023.
  • The company submitted the form on July 14, 2023, more than two years after the deadline.
  • EPA alleged that the late reporting of each chemical was a separate violation of federal chemical-reporting rules.
  • Colgate-Palmolive agreed to a $930,000 civil penalty and certified that it now complies with the applicable requirements.
  • The company admitted EPA’s jurisdiction but neither admitted nor denied the specific factual allegations.

This order documents a reporting failure. It does not identify a chemical release, an unsafe product, an exposure, or an injury caused by the delayed filing.

47Chemical substances included in the delayed 2020 reporting-cycle submission
$930,000Civil penalty Colgate-Palmolive agreed to pay
July 2023Submission date for a report due January 29, 2021

The filing arrived after an inspection

A federal chemical report due on January 29, 2021 did not reach the Environmental Protection Agency until July 14, 2023. It included 47 substances that Colgate-Palmolive had imported in reportable quantities during one or more of the calendar years from 2016 through 2019.

EPA discovered the missing filing while inspecting the company’s Piscataway, New Jersey facility on March 30, 2023 and requesting import records associated with its headquarters at 300 Park Avenue in New York. The order says the legal and logistical arrangements for those imports were made or finalized at the headquarters, which the reporting rules treated as the site of import.

The appendix runs for two pages. It includes familiar names such as hydrogen peroxide, pine oils and terpineol, alongside dozens of substances identified by systematic chemical names and registry numbers. Their presence on the list establishes that EPA considered them reportable in this matter. It does not, by itself, establish that the substances were unsafe.

How an importer became responsible for a manufacturing report

Under the Toxic Substances Control Act reporting framework described in the order, importing a chemical for commercial purposes counts as manufacturing it. Companies that cross applicable volume thresholds must submit information through the Chemical Data Reporting program.

The general threshold cited by EPA is 25,000 pounds of a chemical at a single site during any covered calendar year. For chemicals subject to certain specified TSCA rules, orders or legal actions, the threshold can be 2,500 pounds. The order says the 47 substances were imported in reportable quantities, but it does not provide the volume of each substance or identify which threshold applied to each one.

Commercial importColgate-Palmolive imported covered chemical substances into the United States.
Reporting thresholdThe quantities triggered federal reporting requirements, according to EPA.
Form U deadlineThe 2020 reporting-cycle submission was due by January 29, 2021.
Late submissionThe form including all 47 substances was filed on July 14, 2023.

EPA also found that every substance was on the agency’s Master Inventory File as of June 1, 2020 and that none was excluded from the reporting requirements. The agency alleged that failing to report each chemical on time constituted an individual unlawful act.

From deadline to final order

January 29, 2021

The extended deadline for the 2020 Chemical Data Reporting submission period passed.

March 30, 2023

EPA inspected the Piscataway facility and requested import records associated with the New York headquarters. The company had not filed the required Form U at that time, according to EPA’s findings.

July 14, 2023

Colgate-Palmolive submitted a Form U that included the 47 substances listed in the order.

October 16, 2025

EPA notified the company that it had preliminarily identified failures to file on time.

December 2025 to August 2026

EPA met with company representatives and reviewed additional information provided during settlement discussions.

August 31 and September 1, 2026

EPA’s regional judicial officer signed the final order on August 31. The document bears a September 1 filing stamp from the regional hearing clerk.

What is proven, alleged and unresolved

The settlement combines several different evidentiary categories. Reading them together without distinction would overstate the result.

β€œNeither admits nor denies the specific factual allegations stated above.”Consent Agreement, Paragraph 33(b)

The parties resolved the case before an administrative complaint was litigated. That means no hearing tested the evidence and no judge made findings after a contested proceeding. The final order ratified the settlement; it did not convert Colgate-Palmolive’s non-admission into an admission.

The documented consequence is a gap in timely reporting

Chemical reporting rules require companies to provide the government with information about covered manufacturing and import activity. In this case, the practical consequence established by the order is that a required submission covering 47 chemicals arrived more than two years after its deadline.

The document does not say that the delay caused an exposure, environmental release, illness or unsafe consumer product. It does not identify any affected worker, consumer or community. It also does not connect the listed chemicals to particular Colgate-Palmolive products.

What the order supports

A required federal filing was late, EPA pursued civil penalties, and the company agreed to pay and certify compliance.

What the order does not support

Claims that the chemicals caused harm, contaminated an area or made a named product unsafe.

That distinction does not make the reporting requirement trivial. A system built around company submissions depends on those submissions arriving when required. But the enforcement record here is about regulatory visibility, not documented chemical injury.

What Colgate-Palmolive accepted

The company agreed to pay the $930,000 penalty within 30 days of the regional judicial officer signing the final order. The agreement provides for interest, handling charges and a late-payment penalty if the debt is not paid on time.

Colgate-Palmolive also certified that it complies with the applicable Chemical Data Reporting requirements and understands its continuing obligation to remain compliant. It waived rights to administrative or judicial review of the final order.

The payment resolves the company’s liability for federal civil penalties tied to the alleged violations described in the agreement. It does not erase future compliance obligations or prevent the government from seeking other relief in circumstances preserved by the order. The document does not announce a consumer refund, environmental project or product change.

Questions the settlement does not answer

  • Why the required submission was not made by the January 2021 deadline.
  • What quantities of each chemical Colgate-Palmolive imported.
  • Whether different reporting thresholds applied to different substances.
  • How EPA calculated the $930,000 settlement amount.
  • Whether the delayed data affected any specific EPA analysis or regulatory decision.
  • Which products or supply chains, if any, involved the listed substances.

The order’s most consequential fact is temporal: information due in January 2021 entered the required filing in July 2023. The settlement imposes a substantial penalty for that delay, while leaving its cause and its broader practical effects outside the public record presented here.

Source: U.S. Environmental Protection Agency Region 2, Consent Agreement and Final Order, In the Matter of Colgate-Palmolive Company, Docket No. TSCA-02-2026-9242, filed September 1, 2026. The order does not include underlying inspection records, chemical-specific import volumes or a separate company statement beyond the positions recorded in the agreement.
Aleeia
Aleeia

I'm Aleeia, the creator of this website.

I have 6+ years of experience as an independent researcher covering corporate misconduct, sourced from legal documents, regulatory filings, and professional legal databases.

My background includes a Supply Chain Management degree from Michigan State University's Eli Broad College of Business, and years working inside the industries I now cover.

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