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Frequent Questions

Chemical Substances Subject to the CDR Rule

  1. General
  2. How do I determine my reporting requirements?
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  1. Manufactured Chemicals (incl. Imported)-Commercial
  2. If a company purchases chemicals and blends them into finished products, with no chemical reactions, is the company required to report these materials?
  3. Is a company a manufacturer if it buys the material and resells it or if the company buys the material and packages it into drums?
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  1. "Toll" Manufacturers
  2. Who is primarily or solely responsible for meeting CDR requirements – the contracting manufacturer or the toll manufacturer? Does the contracting company, have to submit information on behalf of the toll manufacturer?
  3. If the contracting manufacturer agrees to report the chemical for the 2012 CDR submission period, does that take the burden off of the toll manufacturer? For example, if Company A tolls for Company X and Company X agrees to report the chemical for 2012, does that absolve Company A from any reporting?
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  1. Importers
  2. Are importers of chemical substances required to report under the CDR rule?
  3. If a company imports three different materials all containing a reportable chemical substance from three different import brokers, who is responsible for reporting?
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  1. Chemical Substances on the TSCA Inventory-General
  2. How does a person access the TSCA Inventory?
  3. Are all substances on the TSCA Inventory subject to the CDR requirements?
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  1. Mixtures
  2. If a company purchases chemical substances from manufacturers and then mixes it for their own use, do they need to report on the mixture?
  3. How are catalysts reported under the Chemical Data Reporting (CDR) Rule?
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  1. Non-TSCA Uses
  2. If a company manufactures a chemical substance for a non-TSCA use, is the company required to submit CDR information for this chemical substance?
  3. A company manufactures Chemical C. Its customers use Chemical C for a variety of uses including the manufacture of a chemical substance to be used as a pesticide active ingredient. Pesticides are exempt from regulation by TSCA. Does the company need to report industrial processing and use data for this chemical substance?
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  1. Exemptions from Reporting
  2. Which chemical substances on the TSCA Inventory are generally exempt from CDR requirements and do not need to be reported?
  3. Many polymers are exempt from CDR regulations. How is “polymer” defined under the CDR rule?
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  1. Production Volume Thresholds
  2. If a company manufactured 31,000 pounds of a reportable chemical substance at one site and 20,000 pounds at another site, does the production volume meet or exceed the threshold for reporting?
  3. How does a company determine whether it has reporting obligations for the 2012 CDR?
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