As a chemical manufacturer or importer in the United States, it’s that time again: the Chemical Data Reporting (CDR) period is upon us. Keeping up with accurate records of your chemical substances and production volumes has never been more crucial!
The Chemical Data Reporting requirement, under the Toxic Substances Control Act (TSCA), mandates that manufacturers and importers submit detailed information on the chemicals they produce or import that are currently in commerce. Similar to a leap year, CDR occurs every four years and enables the EPA to collect and review data related to chemical exposure, ensuring public safety from potential hazards. For 2024, the reporting period spans from June 1 to September 30, making it essential to assess your regulatory responsibilities under this rule.
The good news is that reporting requirements are based on specific thresholds. For the 2024 reporting period, you need to report if you manufactured or imported 25,000 pounds or more of any chemical substance listed on the TSCA Inventory at any site during any of the reporting years (2020 to 2023). If this threshold is met, you must report the total annual production volume for each of these years. Some chemicals might be subject to additional regulations, such as the Significant New Use Rules, which impose stricter controls and require reporting for quantities of 2,500 pounds or more per site.
However, there are exemptions available. Certain groups, like small manufacturers, and specific activities may be exempt from reporting. For example, polymers, microorganisms, naturally occurring substances, water, and some forms of natural gas are fully exempt from reporting. Additionally, if the EPA has classified your chemical substance as having "low current interest," you may be exempt from reporting your industrial processing and use information.