EXPLAINER, UPDATED OCTOBER 14, 2026
Is a glowing lead test kit legal to sell in the U.S.?
Every kit that finds lead by making it glow green under a UV light works because of one chemical, methylammonium bromide. Federal chemical law says who may make or import that chemical for sale. This page lays out the statute, the one argument sellers make around it, EPA's public record as it stands today, and how to check any seller in two minutes.
Not on the InventoryMethylammonium bromide (CAS 6876-37-5) is not on the TSCA Chemical Substance Inventory, so it is a "new chemical substance" under the Act.
2 cases on fileEPA's ChemView lists two Section 5 submissions for the substance. Both are Fluoro-Spec's.
L-25-0206Fluoro-Spec's Low Volume Exemption: received Sept 5, 2025, granted, effective Dec 18, 2025. Listed on EPA's exemptions table.
Written by Fluoro-Spec Inc, which holds one of the exemptions discussed below. Every quotation is from the statute, the regulations or EPA's own database, with the source linked, so you can check each one. It is an explanation of public law and public records, not legal advice for your situation.
What TSCA is, in one paragraph
The Toxic Substances Control Act is the 1976 federal law that gives EPA authority over chemical substances in U.S. commerce. Its core device is a list: the TSCA Chemical Substance Inventory. A substance that is on the Inventory is an "existing" chemical. A substance that is not on it is a "new chemical substance," and new chemical substances cannot be manufactured or imported for commerce until they go through Section 5 of the Act: either a Premanufacture Notice reviewed by EPA, or one of the exemptions EPA grants by rule. The duty sits with the manufacturer or importer. For this product category the whole question comes down to one substance.
15 U.S.C. § 2602(11), definitions
"The term 'new chemical substance' means any chemical substance which is not included in the chemical substance list compiled and published under section 2607(b) of this title."
15 U.S.C. § 2602(9)
"The term 'manufacture' means to import into the customs territory of the United States (as defined in general note 2 of the Harmonized Tariff Schedule of the United States), produce, or manufacture."
15 U.S.C. § 2604(a)(1)(A), Section 5
"Except as provided in subparagraph (B) of this paragraph and subsection (h), no person may (i) manufacture a new chemical substance on or after the 30th day after the date on which the Administrator first publishes the list required by section 2607(b) of this title, or (ii) manufacture or process any chemical substance for a use which the Administrator has determined, in accordance with paragraph (2), is a significant new use."
Subparagraph (B) is the Premanufacture Notice route. Subsection (h)(4) is the exemption route, under which EPA "may, upon application and by rule, exempt the manufacturer of any new chemical substance from all or part of the requirements of this section" when it finds no unreasonable risk; the Low Volume Exemption at 40 C.F.R. § 723.50 is the rule EPA issued under it.
15 U.S.C. § 2614, Section 15, prohibited acts
"It shall be unlawful for any person to (1) fail or refuse to comply with any requirement of this subchapter or any rule promulgated, order issued, or consent agreement entered into under this subchapter ... (2) use for commercial purposes a chemical substance or mixture which such person knew or had reason to know was manufactured, processed, or distributed in commerce in violation of section 2604 or 2605 of this title ..."
The chemical in the bottle
A glow-type lead test contains a solution of methylammonium bromide in isopropyl alcohol. Sprayed on lead, the methylammonium bromide and the lead form a lead-halide perovskite that glows green under 365 nm UV. Isopropyl alcohol is on the Inventory. Methylammonium bromide, CAS 6876-37-5, is not. The Inventory lists substances by chemical identity, so the question for any kit is simply whether the methylammonium bromide in it was manufactured or imported by someone with a Section 5 basis.
"It's just a mixture of approved chemicals"
This is the argument you will hear. Two versions of it exist, and the statute answers both.
Version one: the bottle is a mixture, and mixtures don't need to be listed. True as far as it goes. The bottle is a mixture of methylammonium bromide and isopropyl alcohol, and TSCA does not require mixtures to be on the Inventory. But a mixture is made of chemical substances, and each of those substances has to be lawfully manufactured or imported in its own right. The alcohol is fine. The methylammonium bromide is the new chemical substance, and it is the one that has to have gone through Section 5.
Version two: we don't buy methylammonium bromide, we mix methylamine with hydrobromic acid. Methylamine and hydrobromic acid are both on the Inventory. Combining them is an acid-base reaction that produces methylammonium bromide. The Act's definition of "mixture" deals with exactly this situation: a combination formed by a chemical reaction counts as a mixture only if none of the substances that make it up is a new chemical substance.
15 U.S.C. § 2602(10), definition of "mixture"
"The term 'mixture' means any combination of two or more chemical substances if the combination does not occur in nature and is not, in whole or in part, the result of a chemical reaction; except that such term does include any combination which occurs, in whole or in part, as a result of a chemical reaction if none of the chemical substances comprising the combination is a new chemical substance and if the combination could have been manufactured for commercial purposes without a chemical reaction at the time the chemical substances comprising the combination were combined."
40 C.F.R. § 720.3, EPA's definitions for the Premanufacture Notice rule
"Mixture means any combination of two or more chemical substances if the combination does not occur in nature and is not, in whole or in part, the result of a chemical reaction; except 'mixture' does include: (1) Any combination which occurs, in whole or in part, as a result of a chemical reaction if the combination could have been manufactured for commercial purposes without a chemical reaction at the time the chemical substances comprising the combination were combined, and if all of the chemical substances comprising the combination are not new chemical substances ..."
"New chemical substance means any chemical substance which is not included on the Inventory."
"Manufacture means to produce or manufacture in the United States or import into the customs territory of the United States."
Methylammonium bromide is a new chemical substance, so the reaction product is not a "mixture" under either definition. Whoever runs that reaction has produced a new chemical substance, which is "manufacture" under the Act, and whoever ships the finished solution into the United States has imported one. The exclusions EPA wrote for substances that form by accident do not reach it either: 40 C.F.R. § 720.30(h) excludes impurities, byproducts and substances that form "incidental to" storage, environmental exposure or end use of some other product. An active ingredient made on purpose, to do the one job the product is sold for, is none of those.
40 C.F.R. § 720.30(h), chemical substances not subject to notice
"The chemical substances described below: (Although they are manufactured for commercial purposes under the Act, they are not manufactured for distribution in commerce as chemical substances per se and have no commercial purpose separate from the substance, mixture, or article of which they are a part.) (1) Any impurity. (2) Any byproduct which is not used for commercial purposes. (3) Any chemical substance which results from a chemical reaction that occurs incidental to exposure of another chemical substance, mixture, or article to environmental factors such as air, moisture, microbial organisms, or sunlight ..."
"Impurity means a chemical substance which is unintentionally present with another chemical substance." (§ 720.3)
Dissolving the salt does not change its identity either. Methylammonium bromide in isopropyl alcohol is methylammonium bromide, the same way salt water is salt and water. The Inventory does not list solutions; it lists the substances in them.
EPA's public record, as of October 14, 2026
Everything below is from EPA's own websites and can be reproduced in a browser. ChemView is EPA's public database of Section 5 submissions; its record for CAS 6876-37-5 flags the substance as not on the TSCA Inventory and lists every new-chemical notice ever filed for it. The exemptions table is EPA's running list of Low Volume Exemption cases and their outcomes.
ChemView, search by chemical identifier 6876-37-5, captured October 14, 2026 (EPA data as of October 8, 2026). The result is "Methanamine, hydrobromide (1:1)," the Inventory-style name for methylammonium bromide.
The "Information Submitted to EPA" panel for the same record, opened from the small marker in the result row. Two New Chemical Notices exist for this substance. No other submission of any kind appears.
The first notice: number L-25-0206, type Low Volume Exemption, company Fluoro-Spec Inc, activity domestic manufacture, use "reactive agent for lead detection," received September 5, 2025.
The second notice: number X-25-0001, also Fluoro-Spec Inc, a Low Release/Low Exposure Exemption application received August 20, 2025 that EPA marked invalid the following month. That is the entire Section 5 record for methylammonium bromide as of EPA's October 8, 2026 data.
EPA's exemptions table, row L-25-0206: received September 5, 2025; initial determination "Conditional Grant" November 25, 2025; final "Grant," effective December 18, 2025. Any other maker or importer of this substance would have its own row here.
A seller who holds an exemption can give you its case number in a sentence, and the number can be checked against these two pages in less time than it takes to read this paragraph. A seller who cannot name a case number, or who answers with a Safety Data Sheet that lists only alcohol, has told you what you need to know.
How to check any seller in two minutes
- Ask what makes it glow. A straight answer names methylammonium bromide and CAS 6876-37-5. The SDS should list it as an ingredient with its CAS number.
- Ask for the Section 5 basis. That means a Low Volume Exemption case number in the form L-YY-NNNN, or a Premanufacture Notice case number in the form P-YY-NNNN, held by the maker or the importer of the reagent in the kit.
- Check the number on ChemView. Go to chemview.epa.gov, enter 6876-37-5 under Chemical Name or Chemical Identifier, click Generate Results, then open the "Information Submitted to EPA" marker on the result. The case numbers listed there are the only Section 5 submissions that exist for the substance.
- Check the outcome. Find the case on EPA's exemptions table. A granted exemption shows "Grant" with an effective date. "Invalid," "Withdrawal" or "Denial" means there is no authorization.
If the seller's answer is "it's a mixture," "it's just alcohol," or "we make it ourselves," the section above is the answer to that.
If you buy with federal money
TSCA puts its duties on the manufacturer and the importer, not on the clinic, the health department or the family using the kit. Using a kit you already have is not a TSCA violation on your part, and nothing on this page should stop anyone from using one. Buying is a different act, and buying with a federal award brings in the cost principles that govern every federal grant.
2 C.F.R. § 200.403, factors affecting allowability of costs
"Except where otherwise authorized by statute, costs must meet the following criteria to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items ..."
2 C.F.R. § 200.404, reasonable costs
In deciding whether a cost is reasonable, "consideration must be given to ... (b) The restraints or requirements imposed by such factors as: sound business practices; arm's-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award."
The practical rule that follows: buy from a manufacturer or importer that holds the Section 5 authorization, and put the case number in the procurement file next to the invoice. For methylammonium bromide the case numbers that exist are on this page. Donated kits are a separate matter. Giving a product away is not a sale, the exemption's conditions bind the exemption holder, and a program that receives donated kits is not spending award funds on them.
What we hold
| Substance | Holder | Case | Status |
|---|---|---|---|
| Methylammonium bromide, CAS 6876-37-5 | Fluoro-Spec Inc | L-25-0206 | Low Volume Exemption, granted, effective December 18, 2025 |
| Sodium rhodizonate (color-change swabs) | Spirochaete Research Labs LLC | L-25-0195 | Low Volume Exemption, granted, effective June 30, 2026 |
Both are on EPA's exemptions table and in ChemView. Our Safety Data Sheet names the active ingredient and its CAS number on page one.
Sources
- Toxic Substances Control Act, definitions, 15 U.S.C. § 2602: law.cornell.edu/uscode/text/15/2602
- TSCA Section 5, manufacturing and processing notices, 15 U.S.C. § 2604: law.cornell.edu/uscode/text/15/2604
- TSCA Section 15, prohibited acts, 15 U.S.C. § 2614: law.cornell.edu/uscode/text/15/2614
- Premanufacture notification, definitions, 40 C.F.R. § 720.3: ecfr.gov
- Chemical substances not subject to notice, 40 C.F.R. § 720.30: ecfr.gov
- Low Volume Exemption rule, 40 C.F.R. § 723.50: ecfr.gov
- Uniform Guidance cost principles, 2 C.F.R. §§ 200.403 and 200.404: ecfr.gov
- EPA ChemView: chemview.epa.gov, record for Methanamine, hydrobromide (1:1), CAS 6876-37-5, data as of October 8, 2026, captured October 14, 2026.
- EPA, Reviewing New Chemicals under TSCA, Exemptions Table: epa.gov, captured October 14, 2026.
- EPA, How to Access the TSCA Inventory: epa.gov/tsca-inventory
Quotations are reproduced from the sources above as retrieved October 14, 2026, with internal cross-references abbreviated by ellipsis. Page by Fluoro-Spec Inc, 690 Route 25A, Suite 3, East Setauket, NY 11733.