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February 26, 2016

2016 TSCA CDR Reporting; It's Not Just for Chemical Manufacturers By John Wellspring, Senior Project Manager

2016 TSCA CDR Reporting; It's Not Just for Chemical Manufacturers By John Wellspring, Senior Project Manager The Chemical Data Reporting (CDR) rule, established as part of the Toxic Substances Control Act (TSCA) and codified in 40 CFR Part 711, requires chemical substance manufacturers, producers, and importers to report, during the 3rd quarter of 2016, information on chemical substances manufactured, produced, or imported by any single site for introduction into commerce. This rule applies to chemical substances in quantities above the general threshold of 25,000 pounds (2,500 pounds for certain designated chemicals) during any calendar year from 2012 to 2015. It's important to note that the 2016 CDR rule contains several changes from the 2012 version of the rule.

Reports are required to be filed by manufacturers and importers and not by those who merely use or mix (without chemical reaction) already manufactured chemical substances. However, byproducts and wastes may be considered to be manufactured if they are introduced back into commerce rather than disposed of as waste or if new chemical substances were formed through reactions as a result of the process that generated the byproduct or waste. Also, the definition of "manufacture" includes extraction, for commercial purposes, of a component chemical substance from a previously existing chemical substance or complex combination of chemical substances. Therefore, recyclers and producers of byproducts for beneficial reuse can be affected by these reporting requirements.

Polymers, enzymes, proteins, rubbers, silicones, microorganisms, natural gas, water, and naturally occurring chemical substances are fully exempt from CDR reporting, and petroleum process streams are exempt from detailed processing and use reporting. There are also exemptions for research and development manufacturers and small manufacturers, including those that generate total annual sales of less than $4 million and those that generate total annual sales of less than $40 million that import or produce less than 100,000 pounds of a chemical substance. For small manufacturers, a separate determination is made for each substance produced.

Reports must be submitted to EPA by September 30, 2016, and are required to contain detailed information on the production and use of any chemical substance that exceeds a reporting threshold. Reports may be filed as early as June 1, 2016, and must be submitted through the Submissions for Chemical Safety and Pesticide Programs (CSPP) module on the EPA Central Data Exchange (CDX). Reports are prepared by completing Form U (one per site) using the EPA CDX CSPP "e-CDRweb" reporting tool and must be certified through CDX by an authorized official of the site that manufactures or imports the chemical substance. More than one chemical can be reported on the Form U, and reports may be prepared by designated representatives on behalf of the site.

For the 2016 CDR, the principal reporting year is calendar year 2015. Full manufacturing, processing, and use information will be required only for 2015 (unless the chemical was not manufactured that year), while only basic information is needed for calendar years 2012, 2013, and 2014. Unless qualifying for reporting exemptions, reports are required to be filed for any non-exempted chemical substances in the TSCA chemical inventory, as contained in the EPA's Substance Registry Service (SRS).

Additional information is available at www.epa.gov/chemical-data-reporting.


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