Respondent failed to submit PMNs at least ninety (90) days before manufacturing (importing) chemicals which constitutes a failure to comply with section 5 of TSCA, 15 U.S.C. ? 2604, which is a prohibited act under section 15(1) of TSCA, 15 U.S.C. ? 2614(1). Respondent also informed EPA that it had manufactured (imported) polymer chemical substances between the calendar years 2018 and 2021 and had failed to comply with the recordkeeping regulations at 40 C.F.R. ? 723.250(j). Respondent also failed to submit proper certifications under section 13 of TSCA prior to importing chemical substances which constitutes a failure to comply with section 13 of TSCA, which is a prohibited act under section 15(3)(B) of TSCA, 15 U.S.C. ? 2614(3)(B).