Frequent Questions

Production Volume Thresholds

A company imports 200,000 pounds of Alloy 123 and knows the percentage of each component in the alloy (see table below). How does the company report for Alloy 123 under the CDR regulation?
An importer with one site in the U.S. imports the same chemical from two different companies (located in two different countries). Does the importer add the amounts from each source together or are they kept separate?
For the 2012 CDR, are domestically bought substances that are used in processes and are reacted to manufacture a product reportable? The final product is not a mixture containing this substance. The substance either is reacted completely, or whatever remains unreacted is sent to waste. Also, is the threshold applied to manufacture and import, or to product sold?
How do manufacturers avoid double counting of chemical substances in intermediates and final products? If a chemical substance is an isolated intermediate during production, that’s to be counted. However, if that same chemical substance is present in the final product, should it be added to the amount of isolated intermediate or should the amount in the final product be reported, assuming that amount is greater than what’s present in the intermediates?
How does a company determine whether it has reporting obligations for the 2012 CDR?
If a company began producing a chemical substance in January 2012, does the company need to send the EPA a CDR report for 2011 with all zeros?
If a company imports 1 million pounds of a mixture containing 90 percent Chemical A, 9 percent Chemical B, and 1 percent Chemical C, how is this reported? Chemicals A, B, and C are all potentially subject to CDR.
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?
What if a company both manufactures and imports a chemical substance at a plant site?

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