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TSCA’s Chemical Data Reporting (CDR) Deadline is Rapidly Approaching - November 30, 2020

The Toxic Substances Control Act (TSCA) stipulates that manufacturers and importers must submit chemical information to the US Environmental Protection Agency in accordance with Chemical Data Reporting (CDR) requirements, which occurs every four years. For the 2020 submission period, the deadline has been extended until November 30, 2020, and must be completed online via the e-CDRweb tool which is found within the Central Data Exchange (CDX). 

Reporting is triggered if the annual production volume at a manufacturing (including importing) site is met during any of the calendar years since the last principal reporting year. For the 2020 submission period, the need to report is based on the production volume for the calendar years 2016-2019. The principal reporting year is calendar year 2019. Manufacturers (including importers) must provide manufacturing, processing and use information for only 2019 and production volume information for 2016, 2017, 2018 and 2019. If your company manufactured or imported 25,000 lb or more of a chemical substance for commercial purposes during any of those years (or >2,500 lb for chemical substances subject to rules, orders or actions) then your company is subject to reporting, unless you meet a qualifying exemption.  Additional information regarding persons subject to reporting can be found at 40 CFR 711.8(b).

This year’s CDR has some key changes over previous reporting cycles. These changes include:

CBI Substantiation – This is now required at the time of submission and substantiation is required for every data element, except for annual production volume and supplier information associated with joint submissions, which are both exempt from substantiation according to TSCA Section 14(c)(2). Confidentiality claims may not be asserted for chemical identities publicly listed on TSCA, certain processing and use data elements and when a response is left blank or designated as “not known or reasonably ascertainable.”Additional information can be found at 40 CFR 711.30.

Small Manufacturer Definition – The EPA modified the “small manufacturer” definition which reduced reporting burdens for chemical manufacturers and small governments without compromising the Agency’s ability to receive exposure information about chemical substances. Additional details regarding the definition of a small manufacturer can be found at 40 CFR 704.3.

Site Identification Information – The EPA now requires reporting of the highest-level foreign parent company (if applicable) in addition to the highest-level domestic parent company.    In addition, up to three NAICS codes (North American Industry Classification System) must be provided per reporting site.  40 CFR 711.15

Reporting Process for Co-manufactured Chemicals – The EPA has broadened the definition of a contract manufacturing company.   The company that produces a chemical substance for another company must either complete the full CDR submission (including processing and use data) for the contracting company, OR the contracting company can initiate the CDR reporting within the CDX tool identifying the co-manufacturer, whereby each party completes their respective portion.  For more information, see 40 CFR 711.22.

More information regarding the above changes and additional changes to the 2020 CDR can be found on the EPA website at the following link:

https://www.epa.gov/chemical-data-reporting/summary-reporting-requirement-changes-due-cdr-revisions-and-small

For more information on TSCA’s Chemical Data Reporting requirements:

https://www.epa.gov/chemical-data-reporting

If you are interested in learning more about the CDR or other compliance requirements under TSCA, please send an email to enquiry@reach24h.com.

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