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Frequent Questions

Part I-Company and Site Identification Information

  1. Sec. A. Parent Company Info (Blocks 1.A.1-1.A.8)
  2. Can EPA clarify how the responsibility will be assigned for reporting chemical substance manufacture and import activities for entities that were acquired or divested since the last submission period? For example, the current owner of a newly acquired facility may not have access to manufacture/import volume information for years before they acquired the facility. Would exemptions be provided for any company engaged in an acquisition or divestiture during the years since the last reporting cycle?
  3. Which company should report if a chemical substance is being manufactured by a joint venture?
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  1. Sec. B. Site Information (Blocks 1.B.1-1.B.8)
  2. A company’s headquarters is responsible for ordering and importing several chemical substances that are sent to warehouses in two other states once they have cleared U.S. Customs. The company does not know which site to report on Form U.
  3. A company that has a DB number for its company headquarters is not in the practice of obtaining D&B numbers for its various facilities. The company does not want to engage in such a practice for commercial reasons (e.g., this would create listings and ratings the company would prefer to be published by D&B solely on the basis of its headquarters entries). Must the company obtain separate site D&B numbers to comply with CDR?
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  1. Sec. C. Technical Contact Info (Blcks 1.C.1-1.C.1)
  2. What role does the technical contact play?
  3. Can two different plant sites within the same company that are both reporting under CDR have different technical contacts?
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