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How Greenchem Industries Buried Four Years of Chemical Import Data

When the Paperwork Disappears: How Greenchem Industries Buried Four Years of Chemical Import Data

In July 2026, a Florida-based chemical importer named Greenchem Industries, LLC agreed to pay $70,600 to settle federal charges that it concealed critical information about the hazardous chemicals it was importing and exporting. For four years, from 2020 through 2023, the company imported thousands of pounds of regulated substances and shipped federally restricted chemicals across international borders without filing the notifications required by the Toxic Substances Control Act.

The violations came to light only after the Environmental Protection Agency conducted a surprise inspection at the company’s West Palm Beach facility in March 2024. Greenchem responded by submitting overdue reports months and years after the legal deadlines had passed. By then, the window for public and regulatory oversight had long since closed.

This is the full story of what Greenchem Industries concealed, how the EPA discovered it, and why the penalty system allows corporations to treat transparency as optional.

The Chemicals They Didn’t Report

Under the Toxic Substances Control Act, any company that imports 25,000 pounds or more of a chemical substance in a calendar year must report that activity to the EPA through the Chemical Data Reporting system. The reports are due every four years and cover a rolling window of the previous four calendar years. The 2024 submission period ran from June 1, 2024, to November 22, 2024.

Greenchem Industries imported Chemicals A and B in reportable quantities during 2020, 2021, 2022, and 2023. Both substances were listed in the TSCA Master Inventory File and were not exempt from reporting requirements. The company was legally required to disclose the volume, use, and distribution of these chemicals by the November 2024 deadline.

It did not.

Instead, the company submitted its Chemical Data Reporting forms only after the EPA inspected its facility and demanded compliance. Greenchem filed amended reports on March 16, 2026, more than a year after the regulatory deadline and only after being formally notified of potential enforcement action.

“Any person who imported for commercial purposes 25,000 pounds or more of a chemical substance… at any single site owned or controlled by that person, in any of the calendar years 2020, 2021, 2022, or 2023, is subject to the CDR requirements for the 2024 submission period.” โ€” 40 C.F.R. ยง 711.8(a)

The specific identities of Chemicals A and B are redacted in the public consent agreement under a confidential business information claim. That means the public cannot verify what was imported, where it went, or what risks it posed. The EPA accepted this claim without requiring disclosure.

The Export Notifications That Never Came

Greenchem Industries also failed to notify the EPA before exporting three additional chemicals: C, D, and E. These substances were subject to special federal restrictions due to their classification under TSCA Sections 5 and 6, which govern significant new uses and unreasonable risks to health or the environment.

When a chemical is subject to a Significant New Use Rule or a Section 6 risk evaluation, any exporter must file a notice with the EPA within seven days of forming an intent to export or on the date of export, whichever comes first. The notice is required for the first shipment to each destination country in a calendar year.

Greenchem exported Chemical C 21 times between August 2021 and 2024. The first shipment occurred on August 13, 2021. The required export notice was due no later than that date. The company submitted the notice on March 6, 2024, more than two and a half years late.

Greenchem exported Chemical D once on December 14, 2023. The notice was due by that date. It was filed on March 6, 2024, nearly three months late.

Greenchem exported Chemical E once on July 12, 2021. The notice was due by that date. It was filed on March 6, 2024, nearly three years late.

All three notices were submitted only after the EPA’s inspection triggered a formal enforcement review. Without that inspection, there is no indication the company would have voluntarily disclosed these shipments.

“Pursuant to 40 C.F.R. ยง 707.65(a)(2), any person exporting a chemical or mixture subject to a SNUR or Section 6 of TSCA is required to submit an export notice to the EPA, postmarked within seven days of forming an intent to export or on the date of export, whichever is earlier.” โ€” Consent Agreement, Section III, Paragraph 25

Once again, the specific identities and destination countries are redacted as confidential business information. The public cannot verify what left the United States, where it went, or what international safety protocols were triggered by the export.

The Inspection That Broke the Silence

On February 13, 2024, the EPA issued a formal Notice of Inspection to Greenchem Industries under Section 11(a) of TSCA, which grants the agency authority to inspect facilities and review records for compliance. The inspection took place on March 11, 2024.

On April 30, 2024, the company submitted records related to its chemical imports and exports. Those records revealed the gaps in reporting that had persisted since 2020.

On July 21, 2025, the EPA issued an Opportunity to Show Cause letter formally notifying Greenchem of the violations and giving the company a chance to contest the findings or negotiate a settlement. Greenchem responded on July 31, 2025. The consent agreement was signed on June 25, 2026, and became effective on July 16, 2026, when the Regional Judicial Officer approved the settlement.

At no point did Greenchem Industries voluntarily disclose the missing reports. Every corrective action occurred only after the EPA initiated enforcement proceedings.

1,581 Days
Time Between Greenchem’s First Unreported Export and the EPA’s Inspection

That is more than four years of chemical commerce conducted in the regulatory shadows.

The Non-Financial Ledger

The Chemical Data Reporting system exists because the public has a right to know what is being manufactured, imported, and distributed in their communities. When a company conceals that information, the harm is not abstract. It is material.

Communities near ports, distribution centers, and industrial facilities rely on regulatory transparency to assess risk, advocate for safety measures, and hold companies accountable. When Greenchem Industries failed to report Chemicals A and B, it deprived local governments, environmental groups, and residents of the data they needed to understand what was entering their air, water, and soil.

Export notifications serve a parallel function on the international stage. When the United States exports a chemical subject to domestic safety restrictions, the destination country has a right to know. The notification triggers diplomatic channels that allow foreign governments to assess whether they want to accept the shipment and under what conditions. When Greenchem exported Chemicals C, D, and E without filing the required notices, it undermined that system of informed consent.

These are not victimless procedural violations. They are deliberate acts of opacity that transfer risk from the company to everyone else.

“Respondent provided no evidence of a definite contractual obligation or equivalent intra-company agreement to export the regulated chemical and, therefore, the notice was due by [the date of export].” โ€” Consent Agreement, Section IV, Paragraphs 36, 40, 44

The EPA’s finding is blunt: Greenchem had no documentation proving it intended to export these chemicals in advance. That means the company was exporting restricted substances on an ad hoc basis without the advance planning that would have triggered the legal notification requirement. The shipments happened first. The paperwork, when it finally came, arrived years later.

Environmental Degradation

Chemical Data Reporting is the foundation of environmental risk assessment. When a company imports thousands of pounds of a substance without disclosure, regulators lose the ability to track cumulative exposure, identify contamination sources, and enforce pollution limits.

Greenchem’s imports of Chemicals A and B occurred during a four-year period that included the height of the COVID-19 pandemic, when regulatory oversight was strained and enforcement actions declined nationwide. The company’s silence during that window created a blind spot that persists even now, because the chemicals’ identities remain confidential.

If Chemicals A and B were used in products that eventually entered waste streams, groundwater, or atmospheric emissions, there is no way for the public or independent researchers to trace that impact back to Greenchem’s imports. The data gap is permanent.

Public Health

The Toxic Substances Control Act’s export notification requirement exists in part because chemicals deemed too dangerous for unrestricted use in the United States should not leave the country without the destination nation’s knowledge. The notification is not a ban. It is a disclosure mechanism that allows other governments to make informed decisions.

When Greenchem exported Chemical C 21 times without notifying the EPA until years later, it denied the destination country the real-time information needed to enforce its own safety standards. If workers handled the chemical without adequate protections, if the substance entered local ecosystems, or if disposal protocols were insufficient, the failure began with Greenchem’s decision not to file the required notice.

The same logic applies to Chemicals D and E. These substances were subject to Significant New Use Rules, meaning the EPA had determined their use posed risks that warranted special scrutiny. Greenchem exported them anyway, without notification, and faced no consequences until an unrelated inspection forced disclosure.

Economic Inequality

Compliance is not free. Small and mid-sized chemical companies without the resources to hire dedicated regulatory staff often struggle to meet reporting deadlines. But Greenchem Industries was not a struggling startup. It operated a facility in West Palm Beach, conducted international trade, and employed a Chief Operating Officer who signed the consent agreement on the company’s behalf.

The $70,600 penalty represents a calculated cost of doing business. Greenchem saved time and money by not filing reports for four years. When the EPA finally caught up, the company paid a fine equivalent to the cost of a luxury sedan and moved on. No criminal charges. No operational restrictions. No requirement to disclose the chemical identities to the public.

Meanwhile, community groups and environmental advocates operate on shoestring budgets, relying on the same Chemical Data Reporting system that Greenchem undermined to identify pollution sources and advocate for stricter regulations. The asymmetry is deliberate. The penalty is designed to be absorbable.

Legal Receipts

The consent agreement is a legal document, and the language is precise. Here is what the EPA said, in its own words, about Greenchem’s conduct:

“Pursuant to 40 C.F.R. ยง 711.15, Respondent was required to submit a 2024 CDR Report to the EPA by November 22, 2024, for any reportable chemical substances manufactured (including imported) for commercial purposes in quantities greater than 25,000 pounds in any calendar year from 2020 through 2023. Respondent imported Chemicals A and B in quantities greater than the reporting threshold during that period (2020-2023); therefore, these chemical substances were subject to the 2024 CDR reporting requirements.” โ€” Consent Agreement, Section IV, Paragraph 32

The EPA is stating a fact: Greenchem was required to report. It did not. That is not a disputed allegation. The company agreed to the settlement without admitting or denying the facts, but it also certified that it had corrected the violations. You cannot correct something that never happened.

“Respondent failed to include Chemicals A and B in its 2024 CDR Report. On March 16, 2026, Respondent amended its 2024 CDR Report to include Chemicals A and B.” โ€” Consent Agreement, Section IV, Paragraph 33

March 16, 2026. That is 16 months after the deadline. The amendment came only after the EPA issued the Show Cause letter in July 2025, which itself came only after the April 2024 inspection forced the company to produce records.

On the export violations, the EPA’s findings are equally direct:

“At the time of the first export by Respondent to [CBI deleted], Chemical C was: (1) subject to a TSCA Section 6 rule; and (2) subject to the export notification requirements of Section 12(b) of TSCA and 40 C.F.R. ยงยง 707.60(a), 707.65(a)(1)(i), and 707.65(a)(2). Accordingly, Respondent was required to submit an export notice to the EPA for Chemical C, postmarked within seven days of forming an intent to export, or on the actual date of export, whichever occurred earlier.” โ€” Consent Agreement, Section IV, Paragraph 36

The legal standard is clear. The company did not meet it. The only question is why the penalty is so low.

Societal Impact Mapping

The Greenchem case is representative of a broader compliance crisis in the chemical industry, where self-reporting requirements are systematically ignored and enforcement actions are rare enough to be treated as acceptable business risks.

Any frequent readers of this website knows this! We cover these kinds of evil ass stories all the time

The Chemical Data Reporting system depends on voluntary compliance. The EPA does not have the resources to audit every chemical importer every year. It relies on companies to file accurate reports on time. When companies like Greenchem choose not to comply, the system breaks down. The public loses access to information. Regulators lose the ability to track cumulative risk. And the companies that do comply are placed at a competitive disadvantage against those that cut corners.

The export notification system suffers from the same structural weakness. The EPA has no way to independently verify every international shipment of restricted chemicals. It depends on exporters to file notices in good faith. When exporters like Greenchem file notices only after being caught, the notification system becomes a retrospective formality rather than a real-time safeguard.

$70,600
The Cost of Four Years of Silence

That is $17,650 per year. For a company engaged in international chemical trade, that is not a deterrent. It is a rounding error.

The “Cost of a Life” Metric

$70,600
One Consent Agreement Fine
$176
Cost Per Month of Non-Compliance (4 Years)

The average American household spends more on groceries in a week than Greenchem Industries paid per month to avoid chemical safety reporting for four years. That is the economic reality of regulatory deterrence in 2026.

If a community group wanted to monitor the chemicals entering their watershed, they would need to raise money, hire consultants, and file Freedom of Information Act requests. If they succeeded in identifying a pollution source, they would need to petition the EPA for enforcement, which could take years. The entire time, companies like Greenchem would continue to operate with minimal oversight.

The asymmetry is structural. The cost of transparency is imposed on the public. The cost of secrecy is a tax-deductible fine.

What Now?

Greenchem Industries, LLC is located at 1401 Forum Way, Suite 600, West Palm Beach, Florida 33401. The company’s Chief Operating Officer, Leo Hernandez, signed the consent agreement on June 25, 2026. His contact information is listed in the public record: leo@greenchemindustries.com, 786-325-2976.

The EPA officials responsible for this case are:

  • Gopal Timsina, Case Development Officer, timsina.gopal@epa.gov, 404-562-9017
  • Rob F. Summers, Attorney-Adviser, summers.robert@epa.gov, 404-562-9523
  • Colleen E. Michuda, Supervisory Attorney, michuda.colleen@epa.gov, 404-562-9685
  • Keriema S. Newman, Director, Enforcement and Compliance Assurance Division, U.S. EPA Region 4

The consent agreement is filed as Docket No. TSCA-04-2026-6005(b) and is publicly available through the EPA’s Regional Hearing Clerk.

If you live in South Florida, you have a right to know what chemicals are being imported into your community. The Chemical Data Reporting database is searchable at epa.gov/cdr. Greenchem’s late-filed reports should now be part of that database. Search for them. Verify the volumes. Cross-reference the uses. If the data is still missing, file a FOIA request.

If you are a journalist covering environmental enforcement, request the unredacted consent agreement. The chemical identities are designated as confidential business information, but that designation is not absolute. The Freedom of Information Act allows for disclosure when the public interest outweighs the business interest. Chemical safety is a textbook case for that standard.

If you are an environmental advocate, use this case as a model for how weak enforcement enables non-compliance. The $70,600 penalty is publicly disclosed. Compare it to Greenchem’s revenue, if you can find it. Calculate the effective deterrence rate. Present that data to your Congressional representatives when they consider EPA funding and TSCA amendments.

And if you are a worker in the chemical industry, know this: the chemicals you handle every day are subject to reporting requirements that your employer may or may not be following. If you suspect non-compliance, you can file a confidential report with the EPA’s Office of Inspector General or with OSHA’s whistleblower protection program. The law prohibits retaliation. The system is far from perfect, but it exists.

Greenchem Industries paid $70,600 to settle this case. The chemicals are still in circulation. The data gap is permanent. The only question is whether the next violation will be caught before it becomes another settlement four years later.

The source document for this investigation is attached below.

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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.

Every post on this site was either written or personally reviewed and edited by me before publication.

Learn more about my research standards and editorial process by visiting my About page

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