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Frequent Questions

Chemical Data Reporting (CDR)

These Frequent Questions are intended to clarify the reporting requirements for Chemical Data Reporting for the 2012 reporting period.

In EPA's August 16, 2011, Chemical Data Reporting rule, the Agency changed the name of its chemical reporting regulation from the Inventory Update Reporting (IUR) Rule to the Chemical Data Reporting (CDR) Rule, which is codified at 40 CFR 711. However, throughout this document, EPA has retained the use of the term "IUR" to reflect historic terminology and has used the term "CDR" to describe the revised reporting requirements under the new rule. In other words, EPA is using "IUR" to refer to the 2006 and earlier submission periods; it's using "CDR" to refer to the 2012 and later submission periods, to which the new rules apply.

These FAQs should be used for guidance only and are not a substitute for the Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) rule. You should carefully review the CDR regulations, located at 40 CFR Part 711, for specific information on how to comply with CDR requirements.

Please see the left margin of this page for links to frequent questions on 2012 Chemical Date Reporting.

  1. General
  2. Guidance and Training I know that EPA has provided both on-line and in person training opportunities and guidance materials to facilitate the electronic reporting, but our company is especially concerned we will not be able to upload our data to the e-CDRweb. Will EPA provide a schema for this purpose?
  3. Guidance and Training Is EPA providing training for CDR reporting?
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  1. Chemical Substances Subject to the CDR Rule
  2. Manufactured Chemicals (incl. Imported)-Commercial Is reporting required if the same chemical changes concentration?
  3. Byproducts Chemical X is formed unintentionally, without any separate commercial purpose, during the manufacture of another chemical, Chemical Y. Furthermore, Chemical X is not separated from Chemical Y. Would it be accurate to describe substance Chemical X as an impurity with no reporting obligation?
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  1. Are You a Mfr. or Importer Required to Report?
  2. Certain Regulated Chemical Substances A chemical that Company B manufactures is the subject of a TSCA section 4(a) test rule proposed in 1999. Is this still active and does it affect the CDR status of the chemical substance? Does it matter that Company B didn’t start to manufacture the chemical substance until 2011?
  3. Small Quantities for Research and Development A company manufactures 26,000 pounds of a chemical substance, uses 2,000 pounds for research and development, and sells the remaining chemical substances for industrial uses. Is CDR required?
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  1. Information You Must Report
  2. Processing and Use Reporting Threshold Company A manufactures over 100,000 lbs of a chemical substance and exports 90% of it. Since the remaining 10% is less than 100,000 lbs, does Company A need to report processing and use information in Part III of the form?
  3. Processing and Use Reporting Threshold Has the threshold for processing and use reporting changed since the 2006 IUR submission period?
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  1. Completing Form U
  2. Part II Sec. B. Manufacturing Information A company imports 30,000 lb of a chemical substance and sends the entire volume directly to various warehouses owned by its customers. How is this reported on Form U?
  3. Part II - Sec. A. Chemical ID (Blocks 2.A.1-2.A.4) A company notices that there are CASRNs for several gas streams listed in the Partially Exempt Petroleum Process Streams listed in §711.6(b)(1) that appear to be molecularly similar to its fractionated products propane, butane and ethane. However, the CASRNs that the company previously used to report these products are not listed as partially exempt. The CASRNs previously used in reporting by the company were: 74-98-6, Propane, C3H8; 106-97-8, Butane, C4C10; and 74-84-0, Ethane, C2H6. The CASRNS of molecularly similar partially exempt petroleum process streams are: 68476-49-3 Hydrocarbons,C2-4, C-3 rich; 68476-42-6 Hydrocarbons, C4-5; and 68606-25-7 Hydrocarbons, C2-4. The company wants to know whether or not these CASRNs would be considered synonyms and if they can use the CASRNs for the partially exempt process streams for their CDR submission.
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  1. Confidentiality Claims & Certification Statements
  2. Part II Chemical & Mfr. Info (Blocks 2.B.4-2.B.20) A company makes a chemical substance which is listed on the public version of the TSCA Inventory. How can the company keep the manner in which it uses the chemical substances confidential?
  3. Part II Chemical & Mfr. Info (Blocks 2.B.4-2.B.20) A company plans to report a chemical substance on the 2012 CDR using the confidential Inventory Accession Number and the generic name that goes with the Accession Number. To maintain the listing of this substance on the confidential Inventory does the chemical identity information need to be claimed CBI on the CDR form and must written responses be provided to the CBI questions up front with the CDR report?
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  1. Other Chemical Data Reporting Issues
  2. Recordkeeping Requirements Are companies required to keep records related to CDR reporting?
  3. Submission Periods After 2012 For which years will EPA be requiring production volume information?
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