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Frequent Questions

Completing Form U

  1. General
  2. Does a whole new Chemical Data Reporting (CDR) Form U need to be completed for each chemical substance?
  3. Can one Form U be submitted for the same chemical substance used at two different sites?
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  1. Reporting Standard
  2. Please provide further clarification on the scope of what would be required under the “known to or reasonably ascertainable by” reporting standard. How would this reporting standard apply to processing and use information? How does this standard differ from the “not readily obtainable standard,” previously applicable to such reporting? Does the change of standard indicate that “extensive file searches and customer surveys” are now expected of submitters in order to assemble data for the purposes of chemical data reporting?
  3. What are some examples of types of information that are considered to be in a person’s possession or control or that a reasonable person similarly situation might be expected to possess, control, or know?
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  1. Part II - Sec. A. Chemical ID (Blocks 2.A.1-2.A.4)
  2. If the substance is confidential, can the Accession Number or the Premanufacture Notice (PMN) case number be used instead?
  3. It would be helpful if the Agency provided a cross-reference list of Premanufacture Notice (PMN) numbers.
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  1. Part II Sec. B. Manufacturing Information
  2. How precisely must the manufactured (including imported) volume be reported?
  3. If both domestically manufactured and imported chemical substances are used at a reporting site, how is that reported?
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  1. Part IV. Joint Submissions (Sections 4.A.- 4.D.)
  2. How will the manufacturer’s information be matched with the foreign supplier’s information if they are filing separately?
  3. When are joint submissions allowed?
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