Respondents failure to submit a PMN at least ninety (90) days before manufacturing (importing) Chemicals A, B, and/or C for commercial purposes 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).13. Respondent also failed to submit proper certifications under section 13 of TSCA prior to importing Chemicals A, B, and C 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), Finally Respondent Ultium Cells processing and use of existing stocks of Chemicals A, B, and C from the date of discovery on January 24, 2023, to March 7, 2023, constitutes a violation of TSCA section 15(2), 15 U.S.C. ? 2614(2)).