Print Page   |   Contact Us
Chemical Data Reporting Rule
Share |
On August 16, 2011, the U.S. Environmental Protection Agency ("EPA”) published an amendment to the TSCA Inventory Update Reporting Rule. The amended rule became effective on September 15, 2011. The amendment, among things, renamed the regulation the Chemical Data Reporting Rule ("CDR”). The amendment applies to the reports due in 2012 and subsequent years. The CDR changes several significant criteria for reporting in the post-2012 period. The major changes are:

1. The reporting frequency now is every 4 years. The next submission period is June 1, 2016 to September 30, 2016. 

2. EPA changed the method for deciding if a manufacturer or importer is subject to reporting. Reporting is required if the production volume of a chemical substance met or exceeded the 25,000 pound threshold in any calendar year since the last principal reporting year (2011 for the 2012 submission period). 

3. The reporting threshold for processing and use information (Part III of the reporting form) is 25,000 pounds for the 2016 submission period and subsequent submission periods. 

4. The reporting threshold is 2500 pounds for a chemical substance subject to a proposed or final rule under TSCA sections 5(a)(2), 5(b)(4) or 6, an order issued under TSCA sections 5(e) or 5(f), or a court order issued in an action initiated under TSCA section 5 or section 7. 

This regulatory summary is provided by IMA-NA Associate Member Holland & Hart LLC. Contact Sheila Jones if you have any questions. 

The regulatory issue briefs section of the IMA-NA website provides information and materials to users of its website for informational purposes only. Neither the regulatory issue briefs section of the IMA-NA website nor the individual presentations are intended to be a substitute for legal advice or the advice of health, safety or environmental professionals. Please consult with legal, health, safety or environmental professionals, as you deem appropriate, for such advice based on the facts relevant to the specific issue or issues facing your business. Accessing the website or reviewing a presentation does not create an attorney-client relationship between the person using the website or reviewing the presentation and the author of that presentation.