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Frequent Questions

Are You a Mfr. or Importer Required to Report?

  1. Small Manufacturers
  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. Are small manufacturers exempt from CDR reporting requirements?
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  1. Certain Regulated Chemical Substances
  2. How does a submitter determine whether a chemical substance is the subject of a rule, proposed or promulgated, an order issued, or relief granted under certain sections of TSCA?
  3. 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. Small Quantities for Research and Development
  2. If a company manufactures a small quantity of a chemical substance solely for research and development, is CDR reporting required?
  3. 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. Articles
  2. 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?
  3. Can imported metal powders ever be considered "articles" regardless of their end use?
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  1. Impurities
  2. Must impurities be reported under the CDR regulation?
  3. 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?
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  1. Non-Isolated Intermediates
  2. Reactants C and D are charged to a vessel where they react to form Chemical P. Chemical E is then added to the reaction vessel and Chemical P is completely consumed in the formation of Chemical Q, which is then drummed for shipment. Is the manufacture of Chemical P subject to CDR requirements?
  3. Does sampling for quality control purposes negate the non-isolated intermediate status of a chemical substance?
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