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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?
  4. Purpose of CDR Is the purpose of CDR to make additions or deletions to the list of substances included on the TSCA Chemical Substance Inventory?
  5. Purpose of CDR What is the difference between the CDR rule and the Toxic Release Inventory (TRI) rule?
  6. Purpose of CDR What is the difference between the Inventory Update Reporting (IUR) Rule and the Chemical Data Reporting (CDR) Rule?
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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?
  4. Exemptions from Reporting A company has facilities to recycle used plastic cartridges. These existing plastic cartridges have been previously manufactured and sold to consumers. The cartridges get returned for recycling. On return, the cartridges are crushed and processed (grinding, fusing and blending, etc.) to form a mixture of pellets. No new materials are added and it is not believed that a chemical reaction is taking place that would chemically change the material into different polymers, etc. It is intended that the original plastic materials are being recycled into pellets and thereafter available for reuse. Are the recycled plastic products subject to CDR requirements?
  5. Production Volume Thresholds A company imports 200,000 pounds of Alloy 123 and knows the percentage of each component in the alloy (see table below). How does the company report for Alloy 123 under the CDR regulation?
  6. Mixtures A company manufactures many different compounds containing the metal magnesium, for example MgSO4, MgO, and MgCl2. Is each compound a reportable chemical substance or are they mixtures of magnesium? Should the amount of magnesium in each substance be aggregated and reported as the total amount of magnesium?
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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?
  4. Impurities A company purchases Chemical X which contains impurities, and then uses Chemical X as a reactant to manufacture Chemical Y. The impurities that were present in Chemical X may then be present in Chemical Y and there may be other impurities in Chemical Y. Must the company now report the impurities in Chemical Y because they are present in a chemical substance that the company has manufactured?
  5. Articles A metal alloy disk containing iron, nickel, cobalt, and other metals is imported and subsequently machined to design specifications and assembled into the final product. The shape of the imported disk is commonly referred to as “near-final-shape,” in that its overall shape and dimensions are largely preserved following the machining process. Does EPA consider the metal alloy disk an article for CDR purposes?
  6. Certain Regulated Chemical Substances A second chemical substance that Company B manufactures is the subject of a TSCA section 4(a) test rule which is listed as having a sunset date of November 2011. Does this test rule still affect the CDR status of the chemical substance?
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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?
  4. Partial Reporting Exemptions How do the “specific chemical substances” get listed for partial exemptions from CDR reporting?
  5. Processing and Use Reporting Threshold If a company manufactures 90,000 lb in 2011, does the company need to report processing and use information for the 2012 CDR?
  6. Partial Reporting Exemptions If a company manufactures more than 100,000 lb of a chemical substance listed as a petroleum process stream at 40 CFR 711.6(b)(1)) and is not the subject of any TSCA actions that would negate its partial exemption, which sections of Form U must be completed?
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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.
  4. Part IV. Joint Submissions (Sections 4.A.- 4.D.) A company plans, as a primary submitter, to submit a joint submission with the supplier of a mixture the company imports. Although the company knows the chemical identity of the chemical substances used in the mixture, the supplier has asked that the identity be kept confidential. In this case, does the company submit a joint submission using the trade name instead of using the chemical name?
  5. Part II Sec. B. Manufacturing Information A company produces over 25,000 lb of a reportable chemical substance. Most of this production is for on-site use but a small amount is sent to another site. How should this be reported?
  6. Part IV. Joint Submissions (Sections 4.A.- 4.D.) As a company generally has no contractual means to require foreign suppliers of already purchased materials to either register with CDX or file a joint submission electronically, what can the company do to ensure that a foreign supplier prepares a secondary 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?
  4. General Can information that is “not known or reasonably ascertainable” be claimed as confidential?
  5. Part I- Co. and Site Info (Blocks 2.B.1-2.B.3) Can the identity and contact information for the person listed as the technical contact for a site be claimed as confidential?
  6. General Did the Agency install a warning system in the reporting tool to remind submitters to complete required substantiation before submitting Form U?
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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?
  4. Submission Periods After 2012 How will the timing of submission period change?
  5. Recordkeeping Requirements If a company qualifies for a small business exemption, does it need to keep CDR records?
  6. Recordkeeping Requirements If a company’s annual production is less than 25,000 lb of a chemical substance must records still be kept?
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