Yes. PFOS and its salts are regulated under EPA's Toxic Substances Control Act significant new use rules (SNURs), and their manufacture, import, and use are severely restricted. Importers of 292330 or 292340 must evaluate whether a SNUR exemption applies and may need to submit a significant new use notice to EPA before importing.

Lecithin is generally recognized as safe (GRAS) for food use, but imported food-grade lecithin is still subject to FDA entry review. The foreign facility must be registered with FDA, and the product must meet applicable food-grade purity standards. Soy-derived lecithin may also require allergen labeling disclosure in finished food products.