Frequent Questions

Sec. A. Parent Company Info (Blocks 1.A.1-1.A.8)

A company has 3 small facilities (1 chemical substance to report) that closed in 2011 and the company cannot reasonably obtain the manufacturing data for the facilities. How should the company complete the form for these facilities?
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?
Company CDE owns CDE Texas. CDE Texas has a site which is also its headquarters. This site is partly owned as a joint venture between CDE Texas and Company CDE, and is partly owned solely by Company CDE. The joint venture part makes certain chemicals, and the solely owned part makes different chemicals. Company CDE has a D&B number for its headquarters at another location but not for the solely owned part of the Texas site. Does Company CDE need to get a site-specific D&B number for the part of the Texas site that it solely owns? Do the two entities need to do separate reporting for the site, one for the jointly owned part and one for the solely owned part?
During the first six months of 2011, Company X manufactured 30,000 pounds of a chemical substance included on the TSCA Inventory and not otherwise excluded from the CDR at a particular site. On July 1, 2011, Company Y purchased Company X, acquiring all the assets of company X and assuming all of the liabilities of Company X. During the last six months of 2011, Company Y manufactured 40,000 pounds of the same chemical substance at the site. Who should report the amounts of the chemical substance manufactured during calendar year 2011?
On January 1, 2012, Company A will sell the portion of its business that conducted manufacturing in 2011. Company B will purchase this portion of the business, acquiring all of its assets and assuming all of its liabilities. Whose company identification should be reported for the “U.S. parent company”? Company A’s because Company A was the owner when the manufacturing occurred? Or Company B’s because Company B was the owner of the submission?
On January 1, 2012, Company ABC will change its name to Company XYZ. What name should be used for CDR reporting, the new name, or the name of the company in 2011?
Which company should report if a chemical substance is being manufactured by a joint venture?

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