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Chemical Data Reporting (CDR)

Petitions for Partial Exemption

EPA maintains a list of partially exempt chemicals for which the CDR processing and use information is of "low current interest" at 40 CFR 711.6(b)(2)(iv). Manufacturers of these listed chemicals are exempt from reporting the processing and use information required by 40 CFR 711.15(b)(4). Chemical substances are included on this list only if EPA has determined that there is low current interest in the processing and use information for that substance.

EPA may amend the list of partially exempt chemicals on its own initiative or in response to a request from the public. The public may submit a petition to request that a chemical be added to or removed from the partial exemption. On this site, you will find information on:

Who can Submit a Petition?

A petition may be submitted by any person, regardless of whether the person manufacturers, imports, or uses the chemical, or is otherwise interested in the chemical. When evaluating the petition, EPA will consider the production volume and use information for all manufacturing or importing sites and all uses. This information is not restricted to the submitting site. Considerations used by EPA when deciding whether to grant the petition are listed at 40 CFR 711.6(b)(2).

Note: The partial exemption listing is chemical-specific, not site- or use-specific. Therefore, when a chemical is listed under the partial exemption in 40 CFR 711.6(b)(2), all manufacturers (including importers) are exempt from reporting the processing and use information required under 40 CFR 711.15(b)(4) for the listed chemical substance.

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How Do I Submit a Petition?

Your petition to amend the partial exemption chemical list must be submitted in writing and must contain the identity of the chemical in question, as well as its Chemical Abstract Service (CAS) Registry Number. If a CAS Registry Number is not known to or reasonably ascertainable by you (the petitioner), an EPA-designated Accession Number for confidential substances or a premanufacture notice (PMN) case number can be submitted in lieu of a CAS Registry Number.

Your petition must also contain a written rationale for the request that provides sufficient specific information addressing the considerations listed below and in 40 CFR 711.6(b)(2)(ii), including citations and relevant documents, to demonstrate to EPA that the collection of the information in 40 CFR 711.15(b)(4) for the chemical in question either is or is not of low current interest. If a request related to a particular chemical is resubmitted, any subsequent request must clearly identify new information contained in the request. EPA may request other information that it believes necessary to evaluate the request. EPA will issue a written response to each request within 120 days of receipt of the request. This response will provide a status report for the petition review.

Submit your petition to the address listed below:

By delivery service:

OPPT CDR Submission Coordinator
Attn: Inventory Update Reporting and Chemical Data Reporting
U.S. Environmental Protection Agency
Office of Chemical Safety and Pollution Prevention
EPA East Bldg., Room 6428
1201 Constitution Avenue, N.W.
Washington, DC, 20004
Phone: 202-564-8958

By mail:

OPPT CDR Submission Coordinator
Mailcode 7407M
Attn: Inventory Update Reporting and Chemical Data Reporting
Office of Chemical Safety and Pollution Prevention
Environmental Protection Agency
1200 Pennsylvania Ave., NW.
Washington, DC 20460

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What Happens to My Petition Once I Submit It?

EPA has established a review process for the petitions. There are several steps in this review process and at any place in this process EPA may contact the petitioner for clarification or additional information. The petitioner may also submit additional information to its petition at any time before EPA issues a final decision. No later than 120 days after receipt of the petition, EPA must issue a response to the petitioner. The response need not have EPA's final decision. However, if EPA does make a final decision before the 120 days has passed, EPA may notify the petitioner immediately.

In making its determination of whether this partial exemption should apply to a particular chemical substance, EPA will consider the totality of information available for the chemical substance in question, including but not limited to, one or more of the following considerations:

  • Whether the chemical qualifies or has qualified in past IUR collections for the reporting of the information described in 40 CFR 711.15(b)(4).
  • The chemical substance's chemical and physical properties or potential for persistence, bioaccumulation, health effects, or environmental effects (considered independently or together).
  • The information needs of EPA, other federal agencies, tribes, states, and local governments, as well as members of the public.
  • The availability of other complementary risk screening information.
  • The availability of comparable processing and use information.
  • Whether the potential risks of the chemical substance are adequately managed.

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