This complaint alleges four violations: manufacture of a new chemical substance without having met the pre-manufacture notice (PMN) requirement of TSCA; knowing use of a chemical manufactured in violation of a TSCA; importation of a new chemical substance without having met the PMN requirement of TSCA; and failing to file a correct certification for the importation of a chemical substance. Counts 1 and 2 pertain to the same chemical; counts 3 and 4 pertain to another chemical. For each chemical, respondent disclosed the manufacture and importation violations and sought credit under the audit policy, but in each instance such credit was denied.