Chemical Data Reporting

General Chemical Data Reporting Questions

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  1. Chemical Data Reporting purpose and history, including the Frank R. Lautenberg Chemical Safety for the 21st Century Act
    • 1.1. What is the difference between IUR and CDR?

      As part of the 2011 IUR Modifications final rule, EPA changed the name of the regulation from the Inventory Update Reporting (IUR) Rule to Chemical Data Reporting (CDR) Rule. The reader should note that wherever IUR is used to refer to the 40 CFR 711 regulations or to future CDR submission periods, IUR and CDR are synonymous.

      Some CDR rule changes were effective for the 2012 CDR and some effective with the 2016 CDR submission period. Changes in reporting implemented for the 2012 CDR submission period included lowered processing and use reporting thresholds, upfront substantiation requirements for confidentiality claims, and a revised list of consumer and commercial product categories. During the 2016 CDR submission period, the remaining CDR changes were put into effect including required reporting for chemical substances with production volumes of 25,000 pounds or greater at a single site in any calendar year since the last principal reporting year, a reduced reporting threshold of 2,500 pounds or greater for chemical substances that are the subject of certain TSCA actions, and the removal of the different reporting threshold for processing and use information.

    • 1.2. Is the purpose of CDR to make additions or deletions to the list of substances included on the TSCA Chemical Substance Inventory?

      No. The purpose of CDR is to collect recent information on the manufacture (including importation); processing; and industrial, commercial, and consumer uses of certain chemical substances currently on the TSCA Inventory. Additions to the TSCA Inventory are made through EPA’s New Chemicals Program (See 40 CFR Part 720).

    • 1.3. What is the difference between the CDR rule and the Toxic Release Inventory (TRI) rule?

      The CDR rule, promulgated under the authority of Section 8(a) of TSCA, requires chemical substance manufacturers (including importers) to report manufacturing data and industrial, commercial, and consumer processing and use information for certain chemical substances on the TSCA Inventory. Under the TRI rule, regulated facilities must report information on the releases and other waste management for chemical substances specified under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA).

    • 1.4. How does the Frank R. Lautenberg Chemical Safety for the 21st Century Act affect the 2016 Chemical Data Reporting?

      Effective June 22, 2016, the Toxic Substances Control Act (TSCA) was amended, including revisions of TSCA section 14 related to confidential information submitted under TSCA. For 2016 CDR submitters, EPA has changed the wording of the CBI certification statement in the reporting system to be consistent with new requirements. EPA is updating the guidance, instructions, and other information documents to be consistent with the new certification language.

      2016 CDR submitters should be aware that the amended section 14(e) limits the duration of many confidentiality claims to 10 years, unless those claims are timely reasserted. EPA will be developing policies, rules, and/or guidance to implement this provision.

      Other changes in the law will affect processes that will take place after the 2016 CDR Form Us are received. Most notably, section 14(g) requires that EPA review and make determinations on all CBI claims for chemical identity made in CDR submissions after the date of enactment. Other CBI information submitted under CDR may be reviewed as part of EPA’s section 14(g) obligation to review a representative subset of other sorts of CBI claims. The Agency’s procedures for CBI reviews are reflected in the regulations at 40 CFR part 2, and the regulations at 40 CFR 711.30 contain the substantiation questions for CDR filings.

    • 1.5. I submitted my 2016 CDR before enactment of the Frank R. Lautenberg Chemical Safety for the 21st Century Act and the change in certification statement. Do I need to resubmit my 2016 Form U?

      No. 2016 CDR Form Us submitted before the date of enactment of the Frank R. Lautenberg Chemical Safety for the 21st Century Act do not need to be resubmitted. However, if you revise your submission, your revision will be certified using the new certification statement.

  2. 2016 Submission Period
  3. Reporting Assistance and Training

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Chemical Data Reporting