EPA’s TSCA Chemical Data Reporting Rule (“CDR Rule”) requires manufacturers and importers to report information on chemical substances which they manufacture or import into the U.S.
Manufacturers or importers of chemical substances that were manufactured or imported in excess of 25,000 pounds in any year since the last principal reporting year (2012-2015) are subject to the TSCA CDR Rule. The submission period for this report ends on September 30, 2016. There is a reduced regulatory threshold of 2,500 pounds for substances subject to certain TSCA actions. The applicable reporting threshold is determined based on the chemical substance’s TSCA status as of June 1, 2016.
Failure to report, late reporting, or inaccurate reporting can result in significant penalties – up to $37,500 per violation per day.
Chemical manufacturers and importers must comply with the requirements for the 2016 Chemical Data Reporting Rule:
Small manufacturers1 are not subject to the CDR Rule unless the chemical substance manufactured or imported is subject to certain proposed or final TSCA rules, orders, or actions.
Reports to EPA must be submitted using the e-CDRweb reporting tool provided by EPA.
1 Total annual sales under $40 million AND production/import ≤100,000 lb (≤45,400 kg) for a particular substance at any owned site.
Total annual sales under $4 million regardless of quantity of substances produced or imported.
Critical Path Services can help you determine what your company’s obligations are under the CDR Rule. We can provide an interpretation of the CDR requirements and help you with the identification of your reportable chemicals. We can also provide assistance in completion of Form U within the eCDR software.