Frequent Questions

Importers

A company receives a chemical substance from a foreign source and uses it as a reactant. The reaction completely consumes the chemical substance. Is this chemical substance considered to be site-limited?
A company transports a chemical substance via pipeline from outside the customs territory of the United States to a plant site in the U.S. Is the company subject to the CDR rule for this chemical substance?
A U.S. company manufactures a reportable chemical substance and has included it on the Form U for its manufacturing site. The U.S. company exports that substance to a Canadian company in Canada. The Canadian company then blends the substance with oil to make a mixture which they import back into the United States. Since the component chemical substance that the Canadian company imports into the United States was at one point domestically manufactured and reported in the United States, does the Canadian company that is importing the mixture containing that substance have to report the substance again as a mixture component?
Although Company S is a non-resident (i.e., non-U.S.) company, Company S is the importer of a chemical substance (shipping directly to Company R, customer in the U.S., and acting as the importer of record for purposes of completing the necessary forms for U.S. Customs, including the payment of duties). Can Company S, an entity that is a non-resident importer, file a CDR Form U?
Are importers of chemical substances required to report under the CDR rule?
Company P’s main office that is doing all of the reporting is located in California. However, the actual shipments are sent to warehouses around the country. In determining the import quantity and whether it exceeds the threshold and is thus subject to reporting, does Company P use the amount going to each location or the total amount that it imports? For example, Company P imports a total quantity of 45,000 pounds of a chemical substance which was shipped to four locations throughout the year. The total quantities shipped to each of the four locations are 15,000 pounds, 15,000 pounds, 9,000 pounds and 1,000 pounds. Is this chemical substance reportable? Does Company P need to complete fur forms showing the actual quantity to each location even though each of the quantities is below the threshold? .
If a company imports three different materials all containing a reportable chemical substance from three different import brokers, who is responsible for reporting?
Is a company operating in a Foreign Trade Zone subject to the CDR rule?
The records that Company Q uses to complete its CDR submission are based on the receipt date at its plant (i.e., when material was added to Company Q’s inventory). When importing at year end some material will clear Customs in 2011 but arrive at the plant in 2012. For example, Customs clears the material on December 27, 2011 but it arrives at the plant on January 3, 2012, at which time it is added to the inventory). Is it permissible for Company Q to use the arrival date at the plant to complete the CDR submission?

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