The CDR rule requires manufacturers and importers of chemical substances listed on the TSCA Inventory to report information about the manufacturing, importing, processing and use of the chemicals. This includes information on chemical substance production volumes, manufacturing sites and uses. TSCA CDR data provides improved information for EPA to better identify and manage risks associated with the chemicals. EPA also publishes the CDR data, although Confidential Business Information (CBI) is excluded.
The Chemical Data Reporting rule provides the most comprehensive source of basic screening level, exposure-related information on chemicals to EPA. These data allow EPA to develop a detailed picture of the chemicals in commerce in the United States, including substance types, quantities, end uses and possible exposure scenarios. EPA then uses the data to support health, safety and environmental protection activities related to chemical manufacturing. This includes chemical risk screening, assessment, priority setting and management.
You may be required to report if you manufacture (including manufacture as a byproduct) or import for commercial purposes chemicals listed on the TSCA Inventory and produced in volumes of 25,000 lbs. or more during each calendar year since the last principal reporting year. Potentially affected entities may include:
▲ Chemical manufacturers
▲ Chemical importers
▲ Manufacturers of a byproduct chemical (i.e., utilities, paper manufacturing, semiconductor and other electronic component
When is reporting due?
The reporting frequency is every four years under the Chemical Data Reporting rule. The reporting deadline for 2016 has been extended until October 31, 2016. The next reporting cycle will be in 2020.
How do you submit Chemical Data Reporting data?
The Chemical Data Reporting (CDR) rule requires all companies to report data electronically using e-CDR web, which is a web- based reporting tool that is part of EPA’s Central Data Exchange (CDX) system. In order to make an electronic submission, companies need to register on CDX and log into e-CDR web. The CDX website can be accessed here
How can TSG assist me?
Chemical Data Reporting Enforcement Action – EPA’s evaluation of the last reporting period, most recently in 2012, has led to enforcement action due to violations under the Chemical Data Reporting (CDR) rule. Reporting and recordkeeping violations under TSCA CDR can incur penalties of up to $37,500 per day, per violation. TSG actively assists companies that have come under EPA scrutiny, helps companies deal with EPA enforcement actions and audits, works with companies to meet CDR requirements, and creates programs to ensure future compliance.
Chemical Data Reporting for 2016 and beyond – TSG assists companies with annual recordkeeping activities and reporting issues during the Chemical Data Reporting (CDR) data collection periods. TSG helps companies gather required data in an organized, professional manner to assist in meeting EPA’s CDR reporting requirements. TSG guides companies through the CDR rule requirements to ensure that companies are prepared to report accurately and on time. In addition, TSG is ready to assist in preparing CDR submissions using the required e-CDR web, EPA’s electronic reporting tool.
Contact TSG to learn how we can help.