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Frequent Questions

"Toll" Manufacturers

Company B is a “toll” manufacturing facility which converts its customer’s, Company A’s, own raw materials utilizing the customer’s technology into the customer’s owned products. Company B charges a “toll” fee for the conversion process and does not own any of the materials and is not selling or marketing the manufactured products. All of the products are returned to Company A for their own disposition. Due to confidentiality agreements, Company B is typically not aware of the end use, but certainly doesn’t know the volumes, markets or uses for the products. However, Company A has indicated that Company B is responsible for completing the CDR. Company B’s position is that Company A is the responsible party since it is their material and Company B has no control over the product, market, applications or uses. What should Company B do?
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?
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?

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