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

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.

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

What is proven, alleged and unresolved

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

“Neither 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.

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