Frequent Questions

Part III - General

A company manufactures Chemical P and distributes it to several customers who consume Chemical P in the production of Chemicals Q and R. Chemicals Q and R are then used in the metal plating industry. Under the CDR regulation, if the company must report Chemical P, must the company also report the uses for Chemicals Q and R on Part III of Form U?
A company manufactures chemical substances but often does not know how these chemical substances are used by downstream customers. Does EPA intend for submitters to send questions to customers requesting information about downstream uses?
A company manufactures more than 100,000 lb of an organic chemical substance, which is used as an intermediate to manufacture other chemical substances. A small amount of the organic chemical substance may be unintentionally present in the reaction product but it does not have a separate commercial purpose. The reaction product is sold for commercial and/or consumer use. How should Part III of Form U be completed for the original chemical substance?
All of a company’s products are used to make commercial products through various process steps by different manufacturers. For Part III, should the company provide information about consumer and children’s uses even if its chemical substance is not the end use product?
Company A manufactures a chemical substance that is used as a component in a larger mixture which is then further processed, bottled and sold to consumers. Should Company A report on uses by its customers in addition to reporting on Company A’s facility that further processes the mixture to complete the end product before it’s sold to consumers?
Company A manufactures an additive for polymer resins and sells it to Formulator F. Formulator F formulates a can coating and sells its product, which contains the additive, to Can Coater C. Can Coater C applies the coating to steel and aluminum cans. The additive is completely reacted when the coating is cured. Can Coater C sells the cans to Paint Formulator P, who fills the coated cans with paint and sells its formulated paint product to the public (consumers). Which company is responsible for reporting for the additive for polymer resins?
Company D’s chemical substances are used in oilfields. Company D is not sure whether use of its chemical substances by oilfield service companies would make it commercial or consumer use, and thus subject to Part III Section B reporting.
How is the use of an organic fertilizer reported in Part III of CDR Form U?
How should industrial, commercial, and consumer uses of fungible commodities be reported when they are distributed via a delivery mechanism shared with other manufacturers?

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